Pollution Prevention for
Compliance and
Enforcement Officers
October 27,1997
Sponsored by:
United States Environmental Protection Agency, Region 8
in conjunction with
The National Enforcement Training Institute
-------
tJfep ฃ/W. ,
A(2cU\ V^-'' &*Mn
Pollution Prevention for V,",'ฃ!yU
"ft Compliance and Enforcement Officers
USPEA, Region 8
October 27, 1997
Agenda
8:30 - 8:45 Registration
8:45 - 9:00 Course Welcome
9:00-9:10 Course Overview
9:10-9:35 What is Pollution Prevention?
9:35 - 9:50 Exercise 1
9:50-10:00 Break
10:00 - 10:15 How Does Pollution Prevention Apply?
10:15-10:45 Identifying Pollution Prevention Opportunities During a Facility
Visit
10:45 - 11:00 Exercise 2
11:00-11:10 Break
11:10- 11:30 Pollution Prevention Patterns
11:30 - 11:45 Discussing P2 with Facility Representatives
11:45 - 12:00 Pollution Prevention Information Resources
12:00 - 1:00 Lunch
1:00- 1:25 Cost Implications of P2
1:25- 1:40 Exercise 3
1:40 - 1:50 Pollution Prevention and the Regulatory Spectrum
1:50 - 2:00 Pollution Prevention Through Compliance Assistance
2:00 -2:10 Using Pollution Prevention to Come Into Compliance
2:10-2:20 Break
-------
2:20- 2:50 Pollution Prevention in Enforcement: Supplemental Environmental
Projects
2:50- 3:20 Exercise 4
3:20- 3:35 Negotiating a SEP
3:35 - 3:45 Break
3:45 -4:15 Exercise 5
-------
Pollution Prevention for
Compliance and Enforcement Officers
USEPA Region 8
October 27, 1997
Table of Contents
Page
Course Overview 1
What is Pollution Prevention? 3
Exercise 1: Using the P2 Definition 7
How Does Pollution Prevention Apply? 9
Identifying Pollution Prevention Opportunities During a Facility Visit 11
Exercise 2: Identifying Pollution Prevention Opportunities .15
Pollution Prevention Patterns 17
Discussing P2 with Facility Representatives 21
Pollution Prevention Information Resources 23
Examples of Compliance Assistance Information 25
Enviro$en$e Brochure 35
Cost Implications of P2 37
Exercise 3: Simple Payback Calculation .41
Pollution Prevention and the Regulatory Spectrum 43
Pollution Prevention Through Compliance Assistance 45
Using Pollution Prevention to Come Into Compliance 47
Pollution Prevention in Enforcement: Supplemental Environmental Projects 49
Exercise 4: Evaluating Proposed SEPs 51
Negotiating a SEP 53
Examples of P2 Evaluation Questions Raised in Negotiating a SEP 55
Exercise 5: ACE Chemical Corporation case study 57
-------
Clean P2 Assessment Appendix A
Model Consent Agreement and Final Order Appendix B
-------
Pollution Prevention For Compliance and Enforcement Officers
USEPA Region 8
October 27, 1997
This form is to be completed by the trainee following completion of the training course. A rating of
1 indicates little or no value or poor quality. A rating of 5 indicates high value or high quality.
WORKSHOP EVALUATION FORM
Instructors:
Please include comments in each blank:
Check appropriate box:
1. Objectives (clear, appropriate)?
Poor
Excellent
1
2
3
4
5
2. Content (organized, relevant)?
Poor
Excellent
1
2
3
4
5
3. Speaker (knowledgeable, responsive)?
Poor
Excellent
1
2
3
4
5
4. Delivery (lively, stimulating, clear, fluid)?
Poor
Excellent
1
2
3
4
5
5. Visual Aids (helpful, well-designed)?
Poor
Excellent
1
2
3
4
5
6. Handouts (helpful, well-designed)?
Poor
Excellent
1
2
3
4
5
7. Application (useful on the job)?
Poor
Excellent
1
2
3
4
5
8. Overall Rating (satisfying, recommendable)?
Poor
Excellent
1
2
3
4
5
Other comments (e.g., training weaknesses/strengths, suitability of course length, adequacy of
facility:
Name (optional):
Department/organization:
-------
Pollution Prevention for Compliance and Enforcement Officers
Course Overview
ฆ1^^i^
Course Objectives
Understand basic P2 concepts
Recognize when P2 will benefit a regulated
facility
Evaluate P2 projects
Course Approach
Lectures on concepts, theories and policies
Examples
Exercises to reinforce ideas presented in
lectures and examples
Discussion
ฆ
-------
Pollution Prevention for Compliance and Enforcement O fficers
What i&PoIlution Prevention?
V i
HMB^aaeK
Objectives
Understand P2 definitions
Review P2 techniques
Review multi-media concepts
Discuss P2 benefits
Overview
Definition
P2 goals
The environmental management hierarchy
P2 benefits
Example
Summary
I
Definition
Pollution prevention is a multi-media
environmental management approach that
emphasizes the elimination of
environmental impacts at the source
'* f tmi in i ฆ ii ' H
v- -
Pollution Prevention Goals
Reduce or eliminate hazardous and solid
waste generation
Achieve or approach zero discharge of
chemicals to air and water
Conserve raw materials and energy
- . t.
Protect ecosystems
: The Environmental Management
Hierarchy
-------
Pollution Prevention for Compliance and Enforcement Officers
Source Reduction
Focuses on eliminating sources of
environmental damage
Can be applied at the facility, municipal,
regional, state and national levels
Is the preferred environmental protection
approach
' I II 1
Source Reduction Targets
Raw material and energy usage
Hazardous and solid waste generation
Chemical releases to the air
Discharges to POTWs and surface waters
Sources of groundwater contamination
Sources of storm water contamination
Activities that destroy ecosystems
m 1
Source Reduction Techniques
Process efficiency improvements
Material substitutions
Inventory control
Improved housekeeping
Preventive Maintenance uVy
In-process recycling or reuse
**
Pollution Prevention Benefits
Reduce costs
Improve process operations
Meet or exceed regulatory compliance
requirements
Improve health and safety
Increase environmental protection
-------
Organic Chemical
Manufacturing
Process Disposal
Wastes: Treatment Systems: Method:
VOCs ~ Boiler or industrial furnace Air
'.Scr N
~ \
Wastewaters ~Wastewater treatment system^~ POTW
\
Sludges and Treatment Media ^
Still bottoms ~ Landfill
-------
EXERCISE 1
Using the P2 Definition
The purpose of this exercise is to practice using the environmental management hierarchy to classify waste
management activities. Read each of the activities below and select the part of the environmental
management hierarchy that corresponds to the activity (i.e., source reduction, recycling, treatment or
disposal). If the scenario is an example of source reduction, identify the type of source reduction
technique that is being used (i.e., process efficiency improvements, material substitution, inventory
control, preventive maintenance or improved housekeeping). Please note that the examples are not
necessarily clear-cut; some examples may have more than one answer.
1. A suburban community establishes additional recycling collection capabilities to accept plastic
containers, yard waste, and household hazardous waste.
~ Source reduction ~ Process efficiency improvements
~ Recycling ~ Material substitution
~ Treatment ~ Inventory control
~ Disposal ~ Preventive maintenance
~ Improved housekeeping
2. A petroleum refinery uses spent caustic from a process as a substitute for basic chemical substances
used to neutralize acidity in waste water treatment.
Source reduction ~ Process efficiency improvements
~ Recycling E3 Material substitution
& Treatment ~ Inventory control
13 Disposal ~ Preventive maintenance
~ Improved housekeeping
3. A local garage replaces its conventional paint guns with high volume, low pressure spray guns.
0 Source reduction t3^Process efficiency improvements
~ Recycling ~ Material substitution
~ Treatment ~ Inventory control
~ Disposal ~ Preventive maintenance
~ Improved housekeeping
4. A community sanitary district provides a training program to local industry on storm water protection
techniques.
~ Source reduction ~ Process efficiency improvements
~ Recycling ~ Material substitution
~ Treatment ~ Inventory control
~ Disposal ~ Preventive maintenance
~ Improved housekeeping
-------
5. A manufacturing plant adds a scrubber to control the release of particulate emissions to the air.
~ Source reduction ~ Process efficiency improvements
~ Recycling D Material substitution
~ Treatment ~ Inventory control
~ Disposal ~ Preventive maintenance
~ Improved housekeeping
6. An industrial vehicle maintenance facility purchases a crusher for used oil filters.
~ Source reduction ~ Process efficiency improvements
El Recycling ^ Material substitution
~ Treatment ~ Inventory control
~ Disposal 0 Preventive maintenance
~ Improved housekeeping
7. An office complex uses biodegradable, non-toxic cleaners in all janitorial activities.
~ Source reduction ~ Process efficiency improvements
~ Recycling 13 Material substitution
~ Treatment ~ Inventory control
~ Disposal D Preventive maintenance
~ Improved housekeeping
8. A warehouse changes its inventory procedures so that new incoming materials are placed behind
existing stock on the storage shelves.
~ Source reduction & Process efficiency improvements
~ Recycling ~ Material substitution
~ Treatment 0 Inventory control
~ Disposal ~ Preventive maintenance
~ Improved housekeeping
9. A wood re-manufacturer leaves stain and solvent containers uncovered to allow contents to dry prior to
disposal of cans.
V"1A
~ Source reduction ~ Process efficiency improvements
~ Recycling U; ^ ~ Material substitution
~ Treatment j JJ 1=1 Inventory control
~ Disposal * ~ Preventive maintenance
~ Improved housekeeping
10. A photofinishing operationpurchases^lver recovery equipment.
~ Source reduction Process efficiency improvements
~ Recycling ; ^ Material substitution
^ Treatment ^ ~ Inventory control
~ Disposal ~ Preventive maintenance
~ Improved housekeeping
-------
Pollution Prevention for Compliance and Enforcement Officers
Overview
The regulated community
Direct releases
Hazardous and solid wastes
Planning
Reporting
The Regulated Community
Private sector
- large manufacturing and production facilities
- small facilities
Government
-Federal v"k ty*
- State
- local
Tribes
Direct Releases
Addresses permitted discharge of chemicals
to the environment
Traditional approach results in releases at
approved discharge limits
P2 reduces loadings through:
- process modifications at facility level
- education at the community level
Hazardous and Solid Waste
Controls treatment and disposal of hazardous
and solid wastes
Traditional approach results in transfers of
chemicals to TSDF or landfill
P2 reduces waste transfer at source
ILisu.
-------
Pollution Prevention for Compliance and Enforcement Officers
Planning
Requires facilities to consider impacts in the
planning process
Traditional approach identifies impact and
control approach
P2 modifies approach to minimize impacts
Reporting
Requires tracking of releases and transfers Z
Traditional approach is to characterize and
Summary
Regulated community faces environmental
requirements
P2 meets requirements and reduces
environmental impacts
-------
Pollution Prevention for Compliance and Enforcement Officers
Identifying Pollution Prevention
Opportunities During a Facility
Visit
Objectives
Understand techniques to identify P2
opportunities
Discuss useful information for evaluating
P2 opportunities
Identify specific activities that will support
P2 opportunity identification
Overview
Definitions
Activities prior to a facility visit
Activities during a facility visit
Activities subsequent to a facility visit
Activities Prior to a Facility Visit
Research facility
Review P2 information sources
Talk with other regulators
Talk with technical assistance program
staff
Definitions
A P2 opportunity is any environmental
impact that might be reduced through
source reduction activities
A P2 opportunity assessment is the
systematic review of facility or area to
identify source reduction activities
A P2 plan is a summary of all source
reduction activities that exist for a facility,
corporation or area
Activities During a Facility Visit
Talk with facility staff
Collect documentation
Observe process
> Build an understanding
Analyze information and observations
-------
Pollution Prevention for Compliance and Enforcement Officers
Talk with Facility Staff
Environmental manager
Production manager/engineer
Workers
Maintenance
Collect Documentation
Examples of Useful Information and Sources
Information:
Waste Generation -
Chemical Release* ซ
Material Uses ^
MateriaE Usage-
Activities
Sources of Information:
- Manifests and management records
ฆฆ EPCRA reponing, permits
* Procedures, flow diagrams
* Purchasing records, utility records
" Observations, flow diagrams and
facility activity descriptions
Observe Process
Inspect processes, work areas, grounds and
material/waste storage areas
Verify information provided by facility
staff
Identify points of generation
Identify points of release
Build an Unders
oiLeroe ^nicedui^" ft aai(^
Note obvious opportunities
H
Analyze Information and Observations
Combine data with the process flow diagram to
characterize process steps
\Rm
Sotvantstrippsr-IOgal. |Surface preparation]
~
|_PaMappUcซtiof^|
Masking -1 lbs
Paint thinnar* 2gaL
PaM Wastes 5 gal
Solvent emissions 30 lbs
Spent solvents 1 gal
Paint thkinars 2 gal
Filters *1 lb
Waste paint 3 qts
Masking -1 lbs
Solvent amissions - 2 lbs
Activities Subsequent to a
Facility Visit
Refer facility to technical assistance
program
Provide technical information j
Reply to questions
Document findings
-------
Pollution Prevention for Compliance and
Enforcement Officers
Summary
As a regulator, you can support the
regulated community in identifying P2
opportunities
Opportunities to help occur before, during
and after facility visits
Information collected throughout this
process will support future regulatory
activities
-------
EXERCISE 2
IDENTIFYING POLLUTION PREVENTION OPPORTUNITIES
Activity Description
Acme Metals and Re-manufacturing, a local salvage and refurbishment yard, is located
on six acres of land at the crossroads of Route 43 and Hunter Valley Road. The other
boundaries of the facility are Trout stream and Smith farm (See Figure 1 below). All
scrap vehicles and metals are piled on asphalt or gravel and are open to the weather.
Activities that occur at the facility are performed on a concrete pad, at the crusher or in a
small re-manufacturing building. Activities include:
Vehicle salvage and crushing
Fluids recovery and recycling (including collection of oils in a 1000-gallon
underground storage tank)
Parts recovery and cleaning (using four contract solvent sinks)
Chrome electroplating on re-manufactured on reformed parts
Chrome removal on parts that will be re-plated
Paint stripping by sanding and solvent wipe
Painting
These activities were identified by a neighborhood group that is concerned that Acme
may be contaminating the Trout stream.
(Qui*
' Ch/P/nt* >
fr/U>c/
NOT TO SCALE
Figure 1. Acme Metals and Re-manufacturing
-------
Based upon this description and Figure 1, identify the environmental concerns or P2
opportunities that exist at this facility.
1. P2 opportunities for potential air releases
2. P2 opportunities for water releases
P2 opportunities for land impacts
4. Any other P2 opportunities
-------
Pollution Prevention for Compliance and Enforcement Officers
Pollution Prevention Patterns
Objectives
Discuss similarities between types of
operations
Review environmental impact patterns that
can be resolved by common P2 options
Answer question: "I'm not an engineer; so
how do I do this stuff?"
Definitions
A P2 opportunity is any environmental
impact that might be reduced through
source reduction activities
A P2 option is a source reduction
technique, technology or procedure that
can be used to eliminate or reduce an
environmental impact or issue
Common Opportunities
Chemical mixing
Cleaning
Surface coating
Process scheduling
Chemical storage
Water use
Product finishing
Using Patterns
Identify the types of resources facilities
will need
Understand P2 options that might apply
Recognize new approaches for
environmental protection tied to processes
of greatest concern
-------
Pollution Prevention for Compliance and Enforcement Officers
Summary
With practice you will see activities in
terms of operations and opportunities
Common P2 options may apply across
industry types
Your role is to identify opportunities
Example
Identify processes that rely upon
Solvent cleaning?
Surface preparation?
Surface coating?
Water?
-------
General Flowsheet for Lithographic Printing
Artwork, Copy, or Other Image
Materials
Film
Photoprocessing
Chemicals
(concentrate &
water)
Plates from Storage or
Plate Manufacturer
Plate Processing Chemicals
Ink
Paper
Fountain Solution
Ink
Paper
Fountain Solution
Cleaning Solvent
Rags
Wastes
Used Film
Wastewater
Silver Recovery
Trash
Untrimmed,
Unbound Product i
Finishing
T
Wastewater
Trash
Paper to recycling
Air Emissions
Paper Wrap to Trash
Paper to Recycling
Air Emissions/Emission Controls
Waste Ink
Dirty Rags
Used Plates
Off-Spec Products
Solvent Vapor
Paper Trimmings
Final Product
-------
Pollution Prevention for Compliance and Enforcement Officers
Discussing P2 with Facility
Representatives
Objectives
Study approaches for promoting P2 in the
regulated community
Understand regulated community
perspectives on P2
Overview
Importance of communication
Perspectives
Barriers to pollution prevention
Approach
Importance of Communication
Every contact with the regulated
community is an opportunity
The right questions can initiate P2 activity
Communication can build trust
Barriers to Pollution Prevention
Company may lack:
- Experienced staff
- Technical information and understanding
- Underlying costs for current environmental
approach
Company staff may not want to change
process that works
-------
Pollution Prevention for Compliance and Enforcement Officers
Approach
Breaking through
Learning about the facility
I
nwwMrai
Breaking Through
Use open-ended questions that will make the
person think:
"Why do you use that chemical? Are there
others?"
"How much does that material cost? What are the
disposal costs?"
"Where does that vent go?"
"How much energy does this system use daily?"
"How long has this process been running in this
configuration?"
Learning about the Facility
Use question sessions to your advantage:
Goal is to know enough to make decisions
and ask questions
Use their explanations and responses to
enhance your understanding
Encourage them to apply their expertise
Summary
Discussion is critical to building an
understanding of impacts and opportunities
Question sessions can be used to spark
interest in P2 alternatives
Dialogue is critical throughout process
-------
Pollution Prevention for Compliance and Enforcement Officers
Websites
Enviro$en$e (http://es.inel.gov)
EPA Homepage (http://www.epa.gov)
Compliance Assistance Centers
Automotive
Printing
Agriculture
Small Business
Metal Finishing
iassss.
Publications
OTS55T]
Pollution Prevention News
Industrial Sector Notebooks
P2 Review
r -I
f E5n
-------
Pollution Prevention for Compliance and Enforcement Officers
Technical Assistance Extensions
Universities
Small business assistance
State assistance programs
Hotlines
% Summary
l P2 information is readily available
| Sources are available for you and the
-------
Automotive Service & Repair
Compliance Assistance
Center - GREENLINK
OVERVIEW
As a commercial/industrial sector, automotive service and repair shops constitute the largest
small quantity generators of hazardous waste in the United States. These shops also may be
subject to a variety of other environmental regulations, including those affecting underground
storage tanks, air emissions, and wastewater discharge. Automotive service and repair shops
throughout the United States can now take advantage of a national compliance information
assistance center, known as GreenLink.
In a joint undertaking, EPA's Office of Compliance and the Coordinating Committee for
Automotive Repair (CCAR), a consortium of 38 industry affiliates, have developed a centralized,
multi-accessible information system on compliance requirements, technology updates, and
pollution prevention programs. The Center also provides referrals to state compliance and
technical assistance providers. The goal of GreenLink is to improve compliance by helping
the automotive service and repair community identify flexible, common sense ways to comply
with the many environmental requirements that automotive businesses are subject to on a daily
basis.
TECHNICAL SUBJECTS COVERED
GreenLink provides information on a variety of topics, including:
Used Oil Management
Floor Drains (Stormwater)
Antifreeze
Asbestos
Underground Storage Tanks
Pollution Prevention Alternatives
Hazardous Waste Identification
Emergency Spill Procedures
Part Solvents
Motor Vehicle Air Conditioning Repair
Air Emissions, Fuels and Vehicle Tampering
Paints and Thinners
ACCESSING THE CENTER
By using a variety of communications technologies, GreenLink is available to anyone 24
hours a day, 365 days a year. A user can call the toll-free number to get voice, facsimile, or
mailed information or use the Internet or bulletin board services (e.g., COMPUSERVE, AMERICA
on-line) to access GreenLink's computerized information system containing the same
The Office of Compliance Fact Sheet Series
January 1997
-------
information that is available through the toll-free number. In addition, GreenLink is capable
of linking to other States's Internet home pages that can provide similar state information, as
these home pages become available. GreenLink's phone number is 1-888-GRN-LINK
(476-5465). The Internet address is http://www.ccar-greenlink.org.
GreenLink PRODUCTS & SERVICES
Plain-language Materials. User-friendly materials that provide information about
compliance requirements, pollution prevention, and technical assistance resources for use by
regional and state assistance and educational programs, trade associations, individual
businesses, citizens, and local governments.
Links between Pollution Prevention and Compliance Goals. Information related to the
automotive service and repair industry to help reduce pollution and increase use of the latest
pollution prevention technologies.
Referral Directory. A directory of federal and state governments, universities, and industry
sources that can provide assistance and information.
Training and Education Directory. An industry directory providing a current calendar of
available environmental courses and providers.
Multi-media consolidated checklist. A checklist allowing inspectors to easily and efficiently
determine the compliance status of any automotive service and repair shop. The checklist
also can be used by individual shop owners as a self-audit tool.
Environmental Curriculum Modules. Individual modules will walk a shop owner or
technician through the appropriate statute, regulation, health issue, and environmental
importance of a given auto service activity.
CONTACTS
For further information, contact Everett Bishop, U.S. EPA (202-564-7032) or Sherman Titens,
CCAR (816-561-8388).
The overriding mission of the Office of Compliance at EPA Headquarters is to improve compliance with
environmental laws. The Office of Compliance achieves this by setting national priorities, developing and
implementing innovative compliance monitoring techniques, collecting and analyzing compliance data,
promoting unique and varied compliance assistance to the regulated community, and supporting
enforcement activity. This Fact Sheet is one in a series, intended to provide general information
regarding the Office of Compliance activities.
The Office of Compliance Fact Sheet Series January 1997
-------
Printing Compliance
\|ฎฃr Assistance Center
PRINTERS' NATIONAL ENVIRONMENTAL ASSISTANCE CENTER
(PNEAC)
OVERVIEW
EPA's Office of Compliance and Pollution Prevention Policy staff have partnered with industry
and state environmental experts to create an environmental assistance center for the printing
industry. The Printers' National Environmental Assistance Center (PNEAC) is a comprehensive
resource, linking trade, governmental, and university service providers to efficiently provide the
most current and complete compliance and pollution prevention information to the printing
industry. Working in collaboration with printing trade associations and other printing industry
experts, regulators, and technical assistance providers, PNEAC seeks to improve printers'
compliance with environmental regulations and reduce their waste and emissions by developing
and delivering a variety of environmental information resources for the printing community.
PARTNERS
Printing Industries of America
Graphic Arts Technical Foundation
Screenprinting and Graphic Imaging
Association International
Gravure Association of America
Flexographic Technical Association
Council of Great Lakes Governors
National Pollution Prevention Roundtable
Center for Hazardous Materials Research
ACCESSING THE CENTER
PNEAC aims to be a multMccessible teleco^unications-based center that will be available via a
1-800 number, e-mail* fax, wd a web site. The Center currently is accessible via the Internet at
address: http://vnrn.hazard.ttittc.edu/pneac/pneac.html.
Environmental Defense Fund
Flexible Packaging Association
National Institute of Standards and Testing
U.S. Environmental Protection Agency
U. of Wisconsin-Extension, Solid &
Hazardous Waste Education Center
Waste Management and Resource
Center, 111. Dept of Natural Resources
The Office of Compliance Fact Sheet Series
January 1997
-------
PRODUCTS AND SERVICES
The PNEAC World Wide Web home page, regularly updated and expanded with current
news, providing summaries of regulatory initiatives and requirements for printers,
compliance policies and guidelines, pollution prevention case studies, sources of additional
information and expertise, schedules of conferences and training events, answers to
common questions, and a place to post questions to industry compliance and pollution
prevention experts.
Fact sheets on a broad range of topics from ink recycling to alternatives for shop towels
and press cleaners.
Participant manual and video from the Green and Profitable Printing video conference.
PRINTECH and PRINT REG listservs, which provide electronic links to technical
information and expertise on pollution prevention technologies and regulatory issues of
concern to printers and government agencies.
Model training packages on printing processes, regulatory issues, and pollution prevention
strategies.
800 number and fax~back service.
Clearinghouse of information, including summaries of regulations (federal and selected
states), "best in class" reports and manuals, checklists, and other guides.
Environmental information and assistance focus group meetings conducted to determine
the needs of small printers.
CONTACTS
ฆ Graphic Arts Technical Foundation-Gary Jones (412-621-6941)
ฆ Printing Industries of America-Ben Cooper (703-519-8114)
ฆ Illinois Waste Management and Research Center-Gary Miller (217-333-8940) and Deb Kramer
(312-265-2036)
ฆ University of Wisconsin-Wayne Pferdehirt (608-265-2361) and Tom Blewett (608-262-0936)
ฆ EPA - Doug Jamieson (202-564-7041)
The overriding mission of the Office of Compliance at EPA Headquarters is to Improve compliance with
environmental laws. The Office of Compliance achieves this by setting national priorities, developing and
implementing innovative compliance monitoring techniques, collecting and analyzing compliance data,
promoting unique and varied compliance assistance to the regulated community, and supporting enforcement
activity. This Fact Sheet is one in a series, intended to provide general Information regarding the Office of
Compliance activities.
The Office of Compliance Fact Sheet Series
January 1997
-------
Agriculture Compliance
Vฎฎ) Assistance Center
AGRICULTURE COMPLIANCE ASSISTANCE CENTER
(AG CENTER)
OVERVIEW
The U.S. Environmental Protection Agency (EPA) Office of Compliance, with the
support of the U.S. Department of Agriculture (USD A), has developed a national
Agriculture Compliance Assistance Center (Ag Center) to provide a base for "first-stop
shopping" for the agriculture community. The Ag Center provides a central location for
obtaining comprehensive, easy-to-understand information about approaches to
compliance that are both environmentally protective and agriculturally sound. The Ag
Center seeks to improve compliance by helping the agricultural community identify
flexible, common sense ways to comply with the many environmental requirements that
affect their business. Initial efforts will focus on providing information about EPA's
requirements.
INFORMATION ACCESS
The Ag Center will rely heavily on existing sources of agricultural information and
established distribution mechanisms. The Ag Center is designed so growers, livestock
producers, other agribusinesses and agricultural information/education providers can
access its resources easily through telephone, fax, mail, and Internet The Internet
address is: http://es.inel.gov/oeca/ag/aghmpg.html.
The Ag Center is coordinated from EPA's Kansas City regional office. This gives it
direct access to a large segment of the agricultural community and first-hand information
on factors that affect the compliance of producers and agribusinesses.
INTEGRATING WITH OTHER AGRICULTURAL AGENCIES
Although USDA and other agricultural agencies provide educational and technical
information, assistance in complying with environmental requirements has not been as
readily accessible. The Ag Center will work with USDA and other federal and state
agencies to provide the agricultural community with a definitive source for environmental
compliance information.
The Office of Compliance Fact Sheet Series
January 1997
-------
The Ag Center plans to provide information on a variety of topics, including:
ฆ Pesticides
ฆ Non-point source pollution
ฆ Groundwater, surface water and
ฆ Animal waste management
ฆ Agricultural worker protection
ฆ Wetlands protection
ฆ Concentrated Animal Feeding
drinking water protection
Operations (CAFOs)
In addition, the Ag Center will support regional and state regulatory agencies in their
efforts to provide compliance assistance to local agricultural communities.
AG CENTER PRODUCTS & SERVICES
Plain-Language Materials. User-friendly materials that consolidate information about
compliance requirements, pollution prevention, and technical assistance resources for use
by regional and state assistance and educational programs, trade associations, individual
businesses, citizens, and local governments.
Links between Pollution Prevention and Compliance Goals. Information related to
agriculture to help reduce pollution and increase use of the latest pollution prevention
methods and technologies.
Identify Ways to Reduce Compliance Costs. Identification of common sense, flexible
methods of reducing the costs of meeting environmental requirements, including
identification of barriers to compliance.
Internet Home Page. A home page regularly updated and expanded with current news,
compliance policies and guidelines, pollution prevention information, sources of
additional information, and expertise and summaries of regulatory initiatives and
requirements.
CONTACT
Ginah K. Mortensen
EPA's Agriculture Compliance Assistance Center
726 Minnesota Avenue, Kansas City, KS 66101
Telephone: (913) 551-7207
Fax: (913) 551-7270
The overriding mission of the Office of Compliance at EPA Headquarters is to improve compliance with
environmental laws. The Office of Compliance achieves this by setting national priorities, developing and
implementing innovative compliance monitoring techniques, collecting and analyzing compliance data,
promoting unique and varied compliance assistance to the regulated community, and supporting
enforcement activity. This Fact Sheet is one in a series, intended to provide general information
regarding the Office of Compliance activities.
The Office of Compliance Fact Sheet Series January 1997
-------
Small Business
(|S&! Compliance Assistance
Centers
Overview The Office of Compliance (OC) - in partnership with industry, academic institutions,
environmental groups, and other federal and state agencies - has established national
Compliance Assistance Centers for four specific industry sectors heavily populated
with small businesses that face substantial federal regulation. These sectors are
printing, metal finishing, automotive services and repair, and agriculture. OC is
working on four new centers for: manufacturers of printed wiring boards, small
chemical manufacturers, municipalities, and transportation.
Products & The purpose of the Centers is to improve compliance of the customers they serve by
Services increasing their awareness of the pertinent federal regulatory requirements and by
providing the information that will enable them to achieve compliance. The Centers
accomplish this by offering the following:
-0- "First-Stop Shopping" - serve as the first place that small businesses and
technical assistance providers go to get comprehensive, easy to understand
compliance information targeted specifically to industry sectors.
4- "Improved Information Transfer" - via the Internet and other means,
create linkages (1) between the small business community and providers of
technical and regulatory assistance and (2) amongst the providers themselves
to share tools and knowledge and prevent duplication of efforts.
4- "Compliance Assistance Tools" - develop and disseminate plain-English
guides, consolidated checklists, fact sheets, and other tools where needed by
small businesses and their information providers.
"Links Between Pollution Prevention and Compliance Goals" - provide
easy access to information and technical assistance on technologies to help
minimise waste generation and maximize environmental performance.
4- "Information on Ways to Reduce the Costs of Compliance" - identify
technologies and best management practices that reduce pollution while
saving money.
The Office of Compliance Fact Sheet Series
January 1997
-------
Existing National Metal Finishing Resource Center (NMFRC). NMFRC provides
Centers technical assistance and information on environmental compliance and pollution
prevention to the metal finishing industry. Contacts: National Center for
Manufacturing Science-Paul Chalmer (313-995-4911); EPA -Scott Throwe (202-
564-7013); Internet: http://www.nmfrc.org
Printer's National Compliance Assistance Center (pneac). PNEAC provides
compliance assistance and pollution prevention information to the printing industry.
Contact: Illinois Hazardous Waste Research and Information Center-Gary Miller (217-
333-8942); EPA - Doug Jamieson (202-564-7041); Internet
http://www.hazard.uiuc.edu/pneac/pneac.html
GREENLlNtf - THE AUTOMOTIVE COMPLIANCE INFORMATION ASSISTANCE
Center. GreenLink provides compliance assistance to the automotive service
industry. To access the center to get voice, facsimile, or mailed information, call the
toll-free number at 1-888-GRN-LINK, or contact the web site at http://www.ccar-
greenlink.org. Contacts: U.S. EPA, Everett Bishop (202) 564-7032; and CCAR,
Sherman Titens (816) 561-8388.
The National Agriculture Compliance Assistance Center. The Center
provides information to help producers of agricultural commodities and their supporting
businesses meet their environmental requirements; prevent pollution before it occurs;
and reduce costs by identifying flexible, common-sense ways to achieve compliance.
Contacts: U.S. EPA, Ginah Mortensen, Telephone: (913) 551-7207: Fax: (913) 551-
7270; Internet http://es.inel.gov/oeca/ag/aghmpg.html
Future Chemical Manufacturers: Emily Chow (202-564-7071).
Centers Printed Wiring Board Manufacturers: Keith Brown (202-564-7124).
Municipalities: Wendy Miller (202-564-7102) or John Dombrowski (202-564-7036).
Transportation Industry: Virginia Lathrop (202-564-7057).
General For general information regarding EPA's compliance assistance centers, contact Lynn
Contact Vendinello at (202) 564-7066.
The overriding mission of the Office of Compliance at EPA Headquarters is to improve compliance with
environmentalbws. The Offlceof Compliance achieves this by setting national priorities, developing and
implementing innovative compliance monitoring techniques, collecting and analyzing compliance data,
promoting unique and varied compliance assistance to the regulated community, and supporting
| enforcement activity. This Fact Sheet is one in a series, intendedto provide general information regarding
| the Office of Compliance activities.
The Office of Compliance Fact Sheet Series
January 1997
-------
National Metal Finishing
(sjZz) Resource Center
OVERVIEW
The National Metal Finishing Resource Center (NMFRC) is the most substantial, comprehensive
environmental compliance, technical assistance, and pollution prevention information source
available to the metal finishing industry. The NMFRC seeks to improve industry compliance
with environmental regulations, and heighten industry awareness of their environmental
responsibilities by providing compliance assistance and information to the user via an Internet
Web Site. The Web Site casts information in a way that makes it accessible to a range of users
and establishes convenient and user-friendly delivery mechanisms. The NMFRC benefits not
only metal finishers, but also the regulatory and technical assistance communities. It is a one-
stop, electronically- linked source for all the information users need on an occasional or regular
basis.
PARTNERS
United States Environmental Protection Agency
National Institute of Standards and Technology Manufacturing Extension Partnership
National Center for Manufacturing Sciences
National Pollution Prevention Roundtable
National Association of Metal Finishers
American Electroplaters and Surface Finishers Society
Metal Finishers Supplier Association
ACCESSING THE CENTER
The center provides assistance and information through the Internet to clients nationwide. The
Internet address is: http://www.nmfrc.org.
PRODUCTS AND SERVICES
The NMFRC provides a variety of products and services to the industry, including:
~ Regulatory Information The NMFRC provides compliance information across
environmental media, including federal regulations, policies, and guidance.
The Office of Compliance Fact Sheet Series
January 1997
-------
PRODUCTS AND SERVICES (Continued)
~ Interpretive Guidance ~ The NMFRC posts all applicable regulatory determinations
made by EPA and its regions.
~ Performance and Cost Comparisons Across Technology Options - The NMFRC
provides users with cost comparisons when selecting among various technology
options, and identifies any associated risks or performance data.
~ Pollution Prevention Case Studies - The NMFRC is available for users to explore
how pollution prevention opportunities can be used to achieve compliance in
regulatory requirements as well as go beyond compliance.
~ Technical Forums The NMFRC allows users to post questions to a forum
moderator, and obtain feedback from peers having faced similar compliance or
performance problems.
~ Vendor Information The NMFRC directory provides information on vendor
location, the equipment and materials each provides, and contact information.
~ Links to Local Technical Assistance Providers, Trade Associations and
Technical Societies - The NMFRC electronically links state, local, and other types
of environmental and technical assistance programs. These programs provide a
comprehensive local network for hands-on assistance to metal finishing facilities. The
NMFRC also provides a central access point for information on the activities of the
major trade associations and technical societies in the industry.
~ User Defined Services The NMFRC continuously takes feedback from users to
better tailor services to their needs.
CONTACTS
For further information contact: National Center for Manufacturing Science- Paul Chalmer (313
995-4911) or U.S. EPA-Scott Throwe (202-564-7013).
The overriding mission of the Office of Compliance at EPA Headquarters is to improve compliance
with environmental laws. The Office of Compliance achieves this by setting national priorities,
developing and implementing innovative compliance monitoring techniques, collecting and analyzing
compliance data, promoting unique and varied compliance assistance to the regulated community,
and supporting enforcement activity. This Fact Sheet is one in a series, intended to provide general
information regarding the Office of Compliance activities.
The Office of Compliance Fact Sheet Series
January 1997
-------
Envii#$en$e
http://es.inel.gov
or, http://www.epa.gov/envirosense
Help Line: (703) 908-2007
Funded by the Strategic Environmental Research and
Development Program (SERDP) and an interagency
partnership of the Environmental Protection Agency
(EPA), Department of Defense (DoD) and Department
of Energy (DOE). Implemented through the assistance
of the National Pollution Prevention Roundtable
(NPPR).
EPA System Managers:
Myles Morse (202) 260-3161
morse.myles@epamail.epa.gov
Louis Paley (202) 564-2613
paley.louis@epamail.epa.gov
Office of Enforcement and Compliance
Assurance Contact:
Jonathan Packman (202) 564-2617
packman .j onathan@epamai 1 .epa. gov
http://www.epa.gov/envirosense/oeca
Federal Facilities Contact:
Isabelle Lacayo (202) 564-2578
layaco. isabel le@epamail .epa.gov
You are welcome to become a partner in
Enviro$en$e. If you have information or
comments to share, please contact the Webmaster.
Hosting the following home pages:
NPPR
National Pollution
Prevention Roundtable
/ i. \ aipp
i;
American Institute for
Pollution Prevention
EPA Compliance Assistance
Centers
Pollution Prevention
Cooperative
Awards:
( Bsmlflnalltt
Nil Aw;>r
-------
What is Enviro$en$e?
Enviro$en$e is a free, public environmental
information exchange system that provides users
with pollution prevention (P2) solutions, compliance
and enforcement assistance information, and
innovative technological insights.
Enviro$en$e strives to be the cutting edge of P2
knowledge by building on the work of a wide array
of resources and allowing users to draw upon the
experiences of federal agencies, state and local
organizations, manufacturers, suppliers, researchers
and others.
The network's primary goal is to provide a one-stop-
shopping service for those who seek P2 information.
The system emphasizes material that can help small
businesses in meeting environmental requirements.
Here are just a few of the resources you can
access by clicking on a button.
Compliance and Enforcement.
Keep current with the latest policy and
guidance news, information on new
regulations, and compliance assistance available from
several compliance assistance centers, industry sector
notebooks, and other sources.
FFLEX. If you are a federal government employee,
you can obtain and customize environmental audit
protocols for your organization from FFLEX (Federal
Facilities Environmental Leadership Exchange).
SEPs. Find out what some companies have done to
meet EPA requirements using Supplemental
Environmental Projects (SEPs).
Sector Notebooks. Access and download
comprehensive air, water, and land pollutant data for
any of 18 industrial sectors including information on
industrial processes, regulations, pollutant release data,
and innovative programs.
Kl
Technical/Research and
Development Information.
EPA-Funded Research Projects, Grants, and
Fellowships. Have easy access to EPA interagency
research funding opportunities as well as past and
present research projects and programs through the
National Center for Environmental Research and
Quality Assurance (NCERQA).
http://www.epa.gov/envirosense/ncerqa
P2 Case Studies. See how companies have
successfully implemented pollution prevention measures
in P2 Case Studies.
Pollution Prevention Programs in
the USA.
EPA P2 Partners for the Environment. Obtain
profiles and technical documents of EPA's P2
partnership programs such as:
33/50
Design for the Environment (DfE)
Common Sense Initiative
Green Lights
WasteWiSe
Energy Star
Procurement Programs
Current P2 Activities. Review the latest P2 activities
at the White House, the Department of Agriculture, and
a dozen other federal organizations.
Solvent Substitution Data Systems.
The Solvent Umbrella. Examine an
integrated set of databases that allows you to
access solvent alternative information, including:
EPA's Solvent Alternatives Guide (SAGE)
Idaho National Environmental Engineering
Laboratory's (INEEL) Hazardous Solvent
Substitution Data System (HSSDS)
INEEL's Solvent Handbook Data System (SHDS)
Ozone Depleting Substance (ODS) and Solvent
Alternatives Databases
EPA's Enviro$en$e Integrated Vendor Database.
International Resources.
Keep abreast of events and technologies in
the international community through the
Ozone/Action Information Clearinghouse or
dozens of other international and country-specific
information resources.
Links to Other Systems.
Easily access numerous other information
resources such as:
Defense Environmental Network and
Information Exchange (DENIX)
DOE Pollution Prevention Clearinghouse (EPIC)
National Pollution Prevention Roundtable (NPPR)
Environmental Protection Agency
American Institute for Pollution Prevention (AIPP)
Material Exchange Systems
Federal, Regional, and State Agencies
Academic Environmental Programs
Environmental Research Projects
Links to P2 web sites via the State and Regional
Internet Cooperative.
News, Resources, Contacts, and
Funding.
Vendor Information. Research vendor
information from the extensive Illinois
Waste Management Research Center (IWMRC) Vendor
Database.
Search.
Find P2 solutions within Enviro$en$e.
Search over 23 datasets including the Illinois Waste
Management Research Center's Techlnfo and
Vendlnfo databases.
Search participating regional and state indexed web
sites.
Focus searches on industrial sectors.
DoD/Joint Service.
Look at DoD's extensive P2 programs and
information resources:
Access information on model P2 Plans.
Search the Joint Service P2 Library database.
-------
Pollution Prevention for Compliance and Enforcement Officers
Cost Implications of P2
m ฆ
Objectives
Review environmental cost accounting
considerations and techniques
Discuss cost considerations
Overview
Environmental cost accounting
Definitions
Limitations of traditional methods
Principles
Payback analysis
Net present value analysis
Environmental Cost Accounting
Goes by many names:
Activity Based Costing
Total Cost Assessment
Life Cycle Costing
Total Cost Accounting
Cost Benefit Analysis
Net Present Value Analysis
Definition of Total Cost
Accounting
Total cost accounting is a procedure used to pi
calculate the total cost of a product or
process including long-term benefits and
liabilities, indirect costs, environmental
impacts, and other costs not typically
assigned to the product or process.
Definitions
Capital costs
Operating costs
Payback period
Net present value
-------
Pollution Prevention for Compliance and
Limitations of Traditional
Methods
Traditional accounting and investment
analysis methods "stack the deck" against
pollution prevention investments by:
- excluding certain categories of costs/savings
- evaluating costs over too short a time horizon
Principles
Assign costs to the activities, processes or
products that generate them
Evaluate costs/savings over a long time
horizon
Include intangibles v\i_ฃ.
Payback Analysis
Determine capital costs
Determine current operating costs
Inventory of Potential Capital
Costs
Purchased equipment Planning/
Materials
Utility systems and
connections
Site preparation
Construction/
Installation
Engineering
Start-up/Training
Permitting
Working Capital
Contingency
Salvage Value
| Inventory of Potential Operating |
Costs |
| Direct Materials
Insurance |
| Direct Labor
Future liability I
1 Utilities
Fines/penalties -
i Waste Management Cost of legal |
1 Regulatory
proceedings -
I Compliance
Personal injury 1
Revenues ซ
Calculate Payback Period
Payback
capital costs
-------
Pollution Prevention for Compliance and Enforcement Officers
Net Present Value Analysis
Calculate capital costs
Calculate future operating costs in nominal
dollars
Discount future operating costs
Add capital costs and discounted future
operating costs
Compare NPV with alternatives
Total cost accounting provides a tool for
evaluating alternatives
Total cost accounting incorporates "non-
traditional" costs
Payback and net present value analysis
both widely used
-------
Exercise 3 - Simple Payback Calculation
A local university currently uses a petroleum distillate solvent sink to clean parts at the
power plant. A contractor services the sink and disposes of the spent solvent. The
contractor charges $112 each time the solvent in the sink is changed. The contractor
changes the solvent once per month. A small aqueous-based parts washer, with enough
capacity to meet the shop's needs, costs $2,750. The annual cost to operate the parts
washer is $150. Calculate the payback period for this opportunity.
Start-up costs: Additional Cost Considerations:
Net current costs:
Net future costs:
Pay back = start-up costs
net current costs - net future costs
= yrs
A city transportation maintenance garage currently generates and disposes of 3,600 gallons
of antifreeze per year at a cost of $15,000. Replacement of disposed antifreeze costs the
facility an additional $13,500 per year. An antifreeze recycler costs $12,000 and has an
annual operational cost of $1,000. Assume that the antifreeze recycler will allow the shop
to reduce antifreeze purchases and waste disposal by 50 percent. Calculate the payback
period for this opportunity.
Start-up costs: Additional Cost Considerations:
Net current costs:
Net future costs:
Pay back = start-up costs
net current costs - net future costs
yrs
-------
3. A local printer currently uses cleaning products that contain EPA-17 chemicals. The EPA-17
cleaner costs $15 per gallon and the printer uses 110 gallons per year. Disposal costs for
the cleaner are $8 per gallon and the shop disposes of 30 gallons per year. The owner is
investigating the possibility of using a petroleum-based substitute for the EPA-17 cleaner.
The substitute costs $18 per gallon and he will need 80 gallons per year. The substitute
cleaner is used in a self-contained sink that costs $500. Disposal charges for the cleaner
are $5 per gallon and the sink will be changed two times per year, generating 40 gallons of
waste each time. Calculate the payback period for this opportunity.
Start-up costs: Additional Cost Considerations:
Net current costs:
Net future costs:
Pay back = start-up costs
net current costs - net future costs
yrs
-------
Pollution Prevention for Compliance and Enforcement Officers
Pollution Prevention and the
Regulatory Spectrum
5SSJ
\ ^4^
Objectives
Understand the role of the regulator in
promoting P2
Understand the policies that can be used to
promote P2
Overview
Role of the regulator
The regulatory spectrum
Role of the Regulator
Discuss general P2 concepts, benefits and
approaches
Provide contact for local or state technical
assistance services
Identify P2 opportunities
Evaluate P2 plans, permit conditions and projects
Observe facility attitude towards environment and
pollution prevention
Document all findings
The Regulatory Spectrum
-------
Pollution Prevention for Compliance and Enforcement Officers
Promoting Pollution Prevention
through Compliance Assistance
1
1 Cum*!ฆฆฆฆฆฆฆฆ
- 5-*- gL *** '* m
-i |i11F
L
Overview
ฆJ Definition
H Policy
ฆJ Approaches
m Likely candidates
I
Definition
Compliance assistance is information or
advice provided by regulators. It is:
Voluntary
Provided during inspections
Policy
For facilities that participate in compliance
assistance programs:
Violations will be documented (depending
on seriousness)
Self-disclosure (usually within 90 days)
will be taken into account
Return to compliance is required
Approaches
Provide materials, training, e-mail or
seminars to regulated community:
In response to a specific inquiry
As part of a sector-based compliance
assistance programs
Upon initiation of the permitting process
As pan of routine compliance activities
During inspections
-------
Pollution Prevention for Compliance and Enforcement Officers
Likely Candidates
Small operations
Small businesses
Less advanced facilities
Cooperative businesses
Summary
Compliance assistance:
Provides support to facilities trying to
comply
Builds trust
* Should be used with discretion
-------
Pollution Prevention for Compliance and Enforcement Officers
Using Pollution Prevention to
Come into Compliance
Objectives
Discuss use of pollution prevention when a
facility is out of compliance
Understand policy
Policy
For a non-compliant facility:
Regulator may provide additional time for
a return to compliance if a P2 solution is
proposed
Regulator and facility must agree to
conditions
Project must yield an aggregate gain in
environmental protection
Approach
Regulator or facility proposes use of policy
Facility identifies and develops P2 project
Regulator and facility negotiate agreement
that includes interim milestones and fall
back position
Evaluation
When applying this policy, the regulator
should:
Consider the seriousness of violation
Determine that the proposed project will
return the facility to compliance
Characterize the additional environmental
benefit that will be obtained
-------
Pollution Prevention for Compliance and Enforcement Officers
-------
Pollution Prevention for Compliance and Enforcement Officers
Definition
A supplemental environmental project is:
a component of an enforcement action that
mitigates a portion of the fine
a project not legally required that exceeds
compliance requirements
an environmentally beneficial project
(preferably a P2 solution)
Maintain strong penalty policy
Encourage P2 alternatives
Voluntary and selective
Overview
Definition
Policy goals
SEP Categories
Nexus
Procedures
em
Public
Pollution reductioJrttoTnrol)
Restoration and p^oiJbiaw
Assessments and ^In-
compliance proiruijlltk
Emergency planning\Lik1 preparedness
-------
Pollution Prevention for Compliance and Enforcement Officers
Nexus
The SEP must be related to the violation:
Directly to the source
Within the geographic area or ecosystem
Other facilities with same problems
Other pollutants or processes of concern
Establish a Penalty
Penalty = economic benefit plus gravity
component
' BEN software
> Will vary depending on your policies and
enforcement posture
Evaluate SEP
Process characterization
Environmental impacts
Economics
Nexus issues
Environmental justice
Schedule
Calculate Allowable Mitigation
With an SEP included in the agreement,
remaining fine should:
- Recover economic benefit plus 10
percent of the gravity or
-25 percent of the gravity component
whichever is greater
ป PROJECT software can be used to
calculate value of the SEP activity (contact
Jonathan Libber at (202) 564-6011)
Summary
SEPs policy is an enforcement tool that
provides flexibility
SEPs should result in additional
environmental protection
SEPs are voluntary
Discretion lies with the regulator
-------
EXERCISE 4
EVALUATING PROPOSED SEPs
The inspection at Stoneybrook Manufacturing Company resulted in 10 major
notices of violation. After fruitless negotiations with the managers, you decide to
take enforcement action against the company. Stoneybrook has a fairly good track
record of implementing pollution prevention projects. The company expresses an
interest in pursuing a SEP with pollution prevention conditions and proposes the
following project. Read the project description and answer the questions.
Proposed SEP Projects
Violations - Improper hazardous waste storage and unpermitted releases of xylene
from the batch mixing area. Project - find an alternative to xylene for cleaning the
mixing tanks and fluid transfer lines.
Excerpt from a letter from Stoneybrooks' lawyers addressed to you:
Stoneybrook's engineers propose testing 2 alternative solvent cleaners and improving the
system currently used to recover the solvent after it rinses the equipment. Specifically, we will test
2 solvents that do not contain EPA 17 listed chemicals. We will identify the alternatives by
working with vendors and our trade association. We will apply the alternative solvent the same
way we are currently applying the xylene. Should these products not prove to be acceptable
alternatives, we will continue to use xylene.
Currently we flush the mixing tanks and fluid transfer lines once with xylene. The
contaminated xylene is collected and drummed for disposal as hazardous waste. It is only used
once prior to disposal. We will develop a closed loop recovery system for the alternative solvent
that enables us to filter out the contaminants on-site and re-use the solvents more than once. We
will investigate the feasibility of initially flushing the dirty tanks and hoses with used solvent and
then completing the wash with fresh solvent.
1. Write five questions you would ask concerning the technical viability of the
project as proposed:
2. What schedule would you propose?
-------
Pollution Prevention for Compliance and Enforcement Officers
The Scenario
Knowing the players
Understanding the case
Recognizing barriers
WWIillPIl i i ' ป d
Knowing the Players
I Size of facility
; Size of corporation
I Attitude of management and staff
; Expertise of management and
environmental staff
fi
A J=|
1: |
Understanding the Case
Compliance history [J
Approach to resolving enforcement action hi
Technical feasibility of approach
Overview
The scenario
Information needs
Picking winners
Establishing a schedule
Discretion
-------
Pollution Prevention for Compliance and Enforcement Officers
Recognizing Barriers
Insufficient capital
Non-viable technologies
Entrenched culture
Lack of management support
Animosity
Information Needs
Project goals and objectives
Technical information on facility and
project
Cost information
Approach and schedule
Picking Winners
Evaluate probability that SEP is technically
feasible
Consider attitude arta-pianagement support
Understand (a^)j!(ctivitiesmd) schedules
Establishing a Project Schedule
Milestones
Fall back positions
Return to compliance
Authority to monitor
Reporting
Project end
Discretion
SEPs are a tool for the regulator
You should reject ill-conceived proposals
Goal is to mitigate fines for increased
environmental protection
Summary
Information in a SEP should be complete
SEP proposal should convince regulator
that project will succeed
Be careful but not paranoid
-------
Examples of P2 Evaluation Questions Raised in Negotiating a SEP
The following list contains examples of the questions enforcement officers would typically raise
when evaluating a pollution prevention SEP proposal. The questions enable compliance officers to
determine whether proposed projects meet the criteria used in evaluating SEP proposals (see the
SEP Checklist attached to the Revised Interim SEP policy dated May 1995). The questions cover
four major areas: technical feasibility, environmental feasibility, economic feasibility and
implementation.
1. Does the SEP appear technically feasible?
For both the current process and the proposed project, request the following information:
A process flow diagram showing all major production steps;
Estimate of current annual production or follow-through for the facility as a whole;
MSDS of all relevant chemicals and quantities used and purchase costs;
Descriptions of waste streams and environmental impacts as well as quantities and waste
management costs (i.e., for each product of concern entering a process, determine the percent
disposed of through wastewater, as air emissions, as solid waste, etc.);
Product information/ technical specifications for proposed new equipment or procedures; and
Description of infrastructure modifications that may be necessary to implement the proposed p2
option (e.g., rewiring electrical systems).
2. Will the project result in cross-media transfers of toxins?
Request descriptions of waste streams and environmental impacts as well as quantities and waste
management costs (i.e., for each product of concern entering a process, determine the percent
disposed of through wastewater, as air emissions, as solid waste, etc.).
3. How innovative is the proposed SEP?
Request estimates of whether the proposed modification is innovative or involves off-the-shelf
technologies, give examples of other facilities that have successfully performed similar
modifications.
4. What are the SEP's anticipated environmental benefits?
Highlight the environmental benefits associated with the proposed p2 option including:
Reductions of toxic substances of concern (e.g., ozone depleting substances, EPA 17
chemicals, extremely hazardous substances, EPCRA 313 chemicals);
Energy or water reductions;
Reductions of air emissions;
Reductions of wastewater;
Reductions of hazardous or solid wastes; and
Reductions of overall facility impacts (land management, non-point sources pollution, wetlands,
etc.).
5. Will the proposed projects have any bearing on environmental justice?
-------
6. What are the anticipated cost savings?
Request the information presented in Exhibit 1 from the facility in order to estimate cost savings
resulting from project implementation:
Exhibit 1 Examples of Cost Information
Direct Costs
Indirect Costs
Liability Costs
Capital expenditures
Administrative costs
Penalties
Buildings
Regulatory compliance costs
Fines
Equipment and installation
Permitting
Personal injury
Utility connections
Recordkeeping and reporting
Property damage
Project engineering
Monitoring
Remediation
Operation and Maintenance
Recurring Expenses or Revenues
Raw materials
Manifesting
Insurance
Labor
Waste disposal
Water and energy
Value of recovered material
7. How will the proposed project be implemented?
Exhibit 2 shows examples of the kind of information that may be included in the implementation
plan.
Exhibit 2 Model Implementation & Tracking Plan
Tasks * ' '' *
. "*
^Organization Responsible
Forfmpiementing^The
"Task^#?"*'
Deadline *'i>
Actual 4
Completion^
Data -' ^
Indicatoi^Thaf Task: Wasn't, rt
Completed
Purchase
equipment
Environmental,
Purchasing Depts.
1/15/95
1/14/95
Receipt from equipment
vendor or purchase order
Receive
equipment
Shipping and Receiving,
Shop supervisor
2/28/95
3/10/95
Invoice from Shipping and
Receiving Dept.
Install equipment
Shop supervisor
3/15/95
3/14/95
Photographs of equipment in
use, receipts for chemicals
used to operate the equipment
-------
EXERCISE 5
ACE MANUFACTURING
ACE manufacturing is a small firm located in an economically disadvantaged
neighborhood in a large city in your state. It is a minority-owned small business that
manufactures metal and composite components. ACE manufacturers components that are
used in the Space Shuttle and the B2 Bomber. A recent inspection uncovered the
following areas of concern:
1. ACE generates hazardous wastes from electroplating, metal cleaning and composite
manufacturing wastes. The electroplating wastes contain high concentrations of
silver. The cleaning and composite wastes contain 1,1,1-Trichloroethane (TCA)
(from cleaning activities) and methyl ethyl ketone (MEK) (from composite
manufacturing). The environmental manager could not produce complete manifests
for disposal of 3 months of wastes (about 9 drums of waste). The environmental
manager was on disability leave and the established procedures were not followed.
He assures you that the same waste hauler was used. Further, the hazardous waste
storage area does not have proper secondary containment, drums are apparently
mislabeled and the storage area also contains a variety of small containers of paints,
solvents and oils.
2. Last year, ACE received and then processed an additional 25 drums of MEK from its
NASA contracting partner. These drums put the facility over the 10,000 pound
threshold for reporting under the Emergent Planning and Community Right-to-Know
Act Section 313 (Toxic Release Inventory). The facility did not file a Form R for
MEK. The environmental manager did not realize that a submission for even a one-
time exceedance was required.
3. The facility exceeded its discharge limits for silver to the local POTW on one
occasion. The facility reported the exceedance to the POTW and the state. The spike
was due to a slow bleed of the silver plating bath solution when the solution was
spent and needed to be replaced.
In general, the facility environmental manager has worked very hard to stay in
compliance. Past problems have been dealt with in a timely fashion. However, the
problem with silver discharge limits has occurred before and the facility has still not
found an adequate system to keep the discharge within permitted limits. It seems that
facility management is unwilling to provide the adequate resources needed for the
environmental manager to establish the proper treatment system.
After several rounds of discussions, your multi-media team proposes the following fines
for the facility:
-------
1. RCRA violations $12,500. Primary concern is that the 9 drums of wastes were not
properly manifested or transported. The environmental manager eventually produces
copies of manifests demonstrating that the drums were disposed of at a permitted
TSDF.
2. EPCRA violation $50,000 for failing to report under TRI. Given the facilities use
rates, it is unlikely that this violation could occur again. However, the facility was in
clear violation of the reporting requirements.
3. CWA violation $8,500 for exceeding discharge limits.
The environmental manager proposes activities to come into compliance or mitigate the
fine as part of a fine settlement discussion. The corrective actions and SEP is described in
more detail below. Your job is to evaluate the entire proposal including the SEP (using
the provided checklist) and determine the best course of action for the state. In reviewing
the SEP you should:
1. Make an initial determination as to whether or not the SEP is appropriate and
complete.
2. Develop any questions you might have for the environmental manager concerning the
SEP.
3. Propose a fine mitigation for the proposed SEP.
-------
ACE PROPOSED ACTIVITIES
AND SEP
ACE proposes the following activities to return to compliance and mitigate as much of the
fine as possible (under the Federal SEP policy):
Actions to Return to Compliance:
ACE recognizes that its sloppy handling of wastes and improper management of the
electroplating bathes have created a problem. ACE has identified the following activities
and actions as a means for ensuring future compliance with all applicable environmental
requirements. ACE also invites EPA back within the month to inspect its new hazardous
waste accumulation point and speak with its new alternate environmental managers.
Specific actions that ACE has completed or is in the process of completing include the
following:
Silver discharges exceeding permitted levels:
The cause of silver discharge above permitted levels is the bleed of spent silver plating
bath solution into the wastewater treatment system. The waste water treatment includes
metal exchange and electrolytic recovery. ACE will discontinue any bleeds of plating bath
solutions into the waste water treatment stream. Rather, these wastewaters will be
drummed, manifested and shipped off-site for silver recovery.
Hazardous waste accumulation area:
The facility has already purchased a portable, enclosed hazardous waste accumulation
building. The building has built-in secondary containment. The building has been placed
upon the concrete pad where the current area was located. The building will be locked
and the fence surrounding the area will be locked.
Paperwork and reporting issues:
The facility believes that the lapse in reporting was due to the environmental manager's
absence. To eliminate the potential for this type of problem in the future, the facility has
sent two of its production engineers to two-week hazardous waste management training
courses. The engineers who work during the day and evening shifts will act as alternates
for the environmental manager and serve to oversee hazardous waste management during
their shifts.
The facility quality assurance will also conduct bi-monthly inspections (unannounced) of
the hazardous waste storage area and will review all hazardous waste manifests prior to
shipment of wastes. The facility quality assurance officer will attend the two-week
hazardous waste manager course within two months of this submission.
-------
Proposed SEP
ACE proposes to replace its current composite manufacturing system with a new gravity
fed composite manufacturing system. The current system (see figure 1) relies upon
methyl ethyl ketone (MEK) as a means for flowing polymer powder in between strands of
carbon fiber. The fibers and polymer are then melded together with pressure and heat to
form the composite. MEK is driven off (for recovery) by the preheat system which is
part of the prepreg unit.
The replacement system will eliminate the use of MEK throughout the process (and cut
usage at the facility by approximately 95%). The new process (see figure 2) will rely
upon gravity and compressed air to insert polymer dust into the carbon matrix. The
matrix and polymer will then be compressed and heated to form the composite. The new
system will eliminate 95% of the MEK used at the facility annually (approximately 6500
pounds).
The system will cost ACE manufacturing roughly $200,000 to change over. The cost
breakdown for the project is as follows:
Start-up costs:
1. New composite pre-preg unit $ 125,000
2. Installation $25,000
3. New air compressor $8,500
4. New power (440V) $ 1,500
5. Training for users $8,500
6. New fittings to integrate new unit with existing production line $20,500
7. Removal of old system $ 11,000 (labor of staff)
Cost benefits associated with new system:
1. Sale of old equipment $57,000
2. Reduce MEK usage $ 12,000/yr.
3. Reduced hazardous waste disposal costs $5,000/yr.
4. Reduced labor for chemical and hazardous waste management $7,500/yr.
ACE has reviewed system performance records and has talked with other manufacturers
who have installed the gravity system. ACE is convinced that the system will work with
their manufacturing process. Further, NASA and the Air Force have approved the new
system to meet the technical specifications of the shuttle and B2 programs.
ACE has contacted the manufacturer of the equipment who promises that the equipment
can be provided within 90 days of ordering. ACE will issue a purchase order, depending
on the amount of fine mitigation, as soon as the state accepts the SEP. ACE proposes that
mitigation of the EPCRA fine would make the project more economically viable for their
operations. ACE projects that the new equipment can be on-line within 90 days of
purchase.
-------
Figure 1: Current Process
Residues
Figure 2: Future Process
-------
Supplemental Environmental Project
Submission Inventory
Completeness
SEP Element Sufficient Insufficient5
~ Project Goals
~
~
~ Process Descriptions:
~
~
~ Flow chart of current activity
~
~
~ Flow chart of future activity6
~
~
~ Mass balance information
~
~
~ Description of SEP:
~
~
~ Nexus of SEP to original violations
~
~
~ Expected environmental benefits
~
~
~ Approach to Implementing SEP:
~
~
~ List of activities
~
~
~ Schedule
~
~
~ Staffing of project
~
~
~ SEP Economic Information:
~
~
~ SEP project costs
~
~
~ Current operating costs7
~
~
~ Future operational costs8
~
~
~ Information Developed by Enforcement Personnel
~ Fall-back Position if SEP Fails or is not Completed ~ ~
~ Rationale for Accepting SEP ~ ~
~ Discussion of Environmental Justice Issues ~ ~
5 If insufficient, either identify questions that will be asked of the submitter or reject SEP proposal.
6 Applicable if SEP directly impacts operation
7 Applicable if SEP directly impacts operation and cost of operation
8 Applicable if SEP directly impacts operation and cost of operation
-------
Supplemental Environmental Project
Submission Inventory
Completeness
SEP Element Sufficient Insufficient1
~ Project Goals ~ ~
~ Process Descriptions: ~ ~
~ Flow chart of current activity ~ ~
~ Flow chart of future activity2 ~ ~
~ Mass balance information ~ ~
~ Description of SEP: ~ ~
~ Nexus of SEP to original violations ~ ~
~ Expected environmental benefits ~ ~
~ Approach to Implementing SEP: ~ ~
~ List of activities ~ ~
~ Schedule ~ ~
~ Staffing of project 0 ~
~ SEP Economic Information: ~ ~
~ SEP project costs ~ ~
~ Current operating costs3 ~ ~
~ Future operational costs4 ~ ~
~ Information Developed by Enforcement Personnel
~ Fall-back Position if SEP Fails or is not Completed ~ ~
~ Rationale for Accepting SEP ~ ~
~ Discussion of Environmental Justice Issues ~ ~
1 If insufficient, either identify questions that will be asked of the submitter or reject SEP proposal.
2 Applicable if SEP directly impacts operation
3 Applicable if SEP directly impacts operation and cost of operation
4 Applicable if SEP directly impacts operation and cost of operation
-------
APPENDIX A
-------
Clean P 2 Assessment
for
C.M. Almy & Son, Inc.
March 10,1997
Center for Technology Transfer
190 Riverside Street
Portland, Maine 04103-1073
Phone 780-1744 FAX 780-1547
-------
The CLEAN-P2 Pollution Prevention Pilot Project is based on a partnership between the United States
Environmental Protection Agency (Region 1 EPA-New England), the Maine Department of Environmental
Protection (DEP), and the Center for Technology Transfer (CTT) and its industry partners. The CLEAN-
P2 program inrMซng the assessment conducted at the Baker Company is supported by the USEPA through
grant No. ME 070102004.
-------
SECTION 1 - INTRODUCTION 1
Background and Purpose ]
Facility Description and History 2
CLEAN-P2 Assessment Team 2
SECTION 2 - PROCESS ANALYSIS 3
Process Description 3
Activity-Based Costs ง
SECTION 3 - COMPLIANCE EVALUATION 7
RCRA / Hazardous Waste 7
Hazardous Waste on Site During the 30 September 1996 Site Visit 7
Hazardous Waste Generator Status 7
Air Emissions D
Wastewater Requirements 9
Storm water Requirements ]q
Site Development U
Fuel Storage Management / Underground Storage Tanks 13
SECTION 4 - IDENTIFICATION/EVALUATION OF P2 ALTERNATIVES 14
Regulatory Compliance Alternatives 14
Hazardous Waste 14
Underground Storage Tank (UST)
Storm water 14
Pollution Prevention Alternatives 15
SECTION 5 - IMPLEMENTATION 17
Compliance-Based Actions ]7
Hazardous Waste {7
Underground Storage Tank 17
Stormwater 17
"Beyond Compliance" Projects lg
Installation of Aboveground Fuel Storage 1 g
Schedule lg
-------
SECTION 1 - Introduction
Background and Purpose
USEPA-New England has initiated a pollution prevention and waste minimization project
in Maine and New Hampshire entitled CLEAN-P2. This is a pilot project intended to
measure the potential for improved environmental performance and compliance through a
technical assistance program which offers enforcement relief to participating companies.
In Maine, the Center for Technology Transfer (CTT) has been contracted by EPA to
implement the CLEAN-P2 project in partnership with the Maine Department of
Environmental Protection (DEP). CTT's role in CLEAN-P2 is to manage the overall
project, develop assessment protocols, assemble multi-disciplinary technical assistance
teams, and lead facility-wide, multi-media pollution prevention assessments. In
conducting these assessments, DEP will work with CTT to provide resources to identify
and evaluate environmental regulatory compliance issues. DEP and CTT will work
together to develop a CLEAN-P2 assessment report for each of the companies that is
assessed.
One of the companies that requested to have a CLEAN-P2 assessment conducted at their
facility was C.M. Almy & Son. The scope of the CLEAN-P2 assessment conducted at
C.M. Almy includes:
A nne-dav assessment of C.M. Almv's metal finishing operation conducted hv a
multi-disciplinarv assessment team. The assessment included reviewing and refining
process flow diagrams, reviewing and refining data on material inputs and losses,
identifying compliance deficiencies, reviewing and refining activity-based costs, and
identifying potential P2 opportunities.
Compile and analyze data/information collected as part of the assessment
Information collected during the assessment was reviewed to allow completion of
process flow diagrams and materials accounting spreadsheets, and to develop
additional information to evaluate pollution prevention opportunities
Prepare CI.FAN-P2 Assessment. This report includes a compilation and analysis of
process data such as material inputs, wastes, and environmental costs as well as well
as an evaluation of environmental compliance, and identification of pollution
prevention opportunities.
Identify One Project That Takes C.M. Almv "Bevnnd Compliance". When a
company improves its operations such that the environment is impacted less than if
that company merely complied with the necessary regulations it is said to go "beyond
compliance". One of the requirements of CLEAN-P2 participants is that they select
at least one project that is technically and economically feasible that will take them
1
-------
beyond compliance, and then implement that project to demonstrate its overall
impact.
Facility Description and History
C.M. Almy & Son, Inc (C.M. Almy) manufactures high quality, hand made liturgical
artifacts including metal objects and vestments. This assessment was limited to the
metalware products part of the business. C.M. Almy employs a total of approximately
100 persons, 12 of these being in the metalware area. Metal products that C.M. Almy
manufactures include brass candle holders, silver and gold plated chalices, plates and
other objects. The processes that are employed to make these products include metal
cutting, machining, annealing, sanding, buffing, welding, engraving, electroplating, and
lacquering.
CLEAN-P2 Assessment Team
The CLEAN-P2 assessment at C.M. Almy & Sons, Inc. included the following team
members:
Peter Moulton, Maine DEP
Mark Arienti, CTT
Stanley Eller, CTT
David McCaskill, Maine DEP
Chris Rushton, Maine DEP
Don Albert, Maine DEP
Carl Trottier, Precision Screw Machine Products
From C.M. Almy, Mr. Michael Fendler, President, Mr. Charles Sprague, Manager of the
metals shop, and Ms. Barbara Hamilton participated in the assessment. Mr. Sprague led
the team on the facility walk-through, and all three answered questions and provided
information on the facility and the manufacturing operations.
2
-------
SECTION 2 - Process Analysis
Process Description
C.M. Almy's metalware shop includes the following processes: machining, annealing,
soldering, buffing, electroplating, lacquer coating and assembly. Figure 1 presents an
overall process flow diagram for the metalworking shop. Although the CLEAN-P2
assessment addresses environmental compliance in the entire metalware shop, the process
analysis presented below focuses on the metal finishing processes, electroplating and
lacquering. Detailed process flow diagrams for these processes are presented in Figures 2
and 3.
Most of the metalware that C.M. Almy produces uses brass as a base metal which is then
silver, gold or nickel plated or lacquered. The overall electroplating process also
includes alkaline cleaning, acid pickling, copper strike, silver strike, and rinsing as
intermediate processes. Another integral part of the overall plating process is recovery of
plating chemicals from drag-out rinses that follow each of the electroplating plating
tanks. Recovery is achieved using a vacuum distillation unit that takes metal-bearing
rinsewater and distills it to produce distilled water and a concentrated metal-bearing
solution. The distilled water is sent back to the rinse and the metal-bearing solution is
used to replenish the plating bath.
The lacquer coating process involves spraying the part with lacquer and sometimes
involves stripping of lacquer when refinishing old parts. Because of the high VOC
content of the lacquer, Almy has tried to identify a water-based substitute. However,
although C. M. Almy has tried many water-based substitutes none have been able to
adhere properly.
Material Inputs and Losses
An important type of information necessary to identify compliance and pollution
prevention opportunities is the amount and type of material inputs and losses such as
solid, liquid, and gaseous by-products or wastes. The primary materials used and losses
generated in the general metalworking operations and presented in Table-1. Materials
used and losses generated in the plating and lacquer coating processes are listed in Tables
2 & 3. The sources of the numbers listed in these tables are: (a) data from an
Environmentally Conscious Manufacturing (ECM) assessment conducted by C.M. Almy
in 1995; (b) responses to a questionnaire filled out by C.M. Almy prior to the CLEAN-P2
assessment (see Appendix A); and (c) additional information collected on the day of the
CLEAN-P2 assessment. Some important points to make about material use and waste
include:
Most of the numbers presented in Tables 1,2 and 3 are not precise numbers based on
analytical measurements or mass balances. They are rough, order-of-magnitude (ฑ
30%) amounts based on manifests, purchase orders, container sizes, etc.
The plating processes generate a small amount of hazardous wastes including
approximately 40 gallons per year of spent cyanide-containing plating solution, 50
3
-------
lbs/yr of spent cyanide-containing filters, and 10 gallons of waste acid solution.
These wastes are generated as follows:
* The spent plating solution is generated when the silver strike, silver plate or
copper strike bath reach a level of contamination which makes them
ineffective. All of these baths have a lifespan of greater than one year and as
much as 6 years.
* The filters operate continuously in all of the cyanide-based plating baths to
remove organic contaminants and particulates. The filter media, which can be
either carbon or polypropylene, is replaced on average about once a month as
it becomes saturated with contaminants.
Approximately 750 gallons per day (gpd) of water is used in the metalware shop, 650
of which is used in flowing rinses in the plating operation. This very small amount
of water use is a result of several pollution prevention actions taken by C.M. Almy in
the last few years including:
* elimination of unnecessary flowing rinses following alkaline cleaning and
following the silver plate still rinse;
* installation of flow restrictors
* installing valves on the individual rinses to shut them off when parts are not
being plated
* installation of covers on the plating tanks to minimize evaporation
* installation of the distillation unit as mentioned above
Wastewater from the plating operation, discharged to the Town of Pittsfield sewer
system, is somewhat less than 650 gallons per day used. The primary reason for this
is that some water evaporates from the baths.
Vapors from the plating tanks, primarily consisting of water vapor but also possibly
containing small amounts of plating bath constituents, are ventilated to the outside.
These vapors are generated only while the tanks are in operation. The tanks are
covered when not in operation.
The lacquer coating process generates approximately 400 lbs/yr of volatile organic
compound (VOC) emissions per year based on the amount of lacquer and thinner
used.
The lacquer stripping process formerly used methylene chloride whose use resulted in
hazardous air emissions and hazardous solid waste. Approximately 1.5 years ago,
C.M. Almy identified an alternative lacquer stripping substance called MagiSol
produced by Chute Chemical. The used MagiSol stripping solution was recently
tested and found to be non-hazardous waste according to RCRA characteristics.
4
-------
For parts cleaning in the buffing operation, C.M. Almy uses an aqueous cleaning
chemical called Penatone. Rinsing after cleaning with Penatone results in
approximately 100 gallons per day of wastewater. Formerly, C.M. Almy used a
vapor degreasing process which used approximately 500 gallons per year of 1,1,1-
trichloroethane (TCA). The relatively new aqueous cleaning process has resulted in
the elimination of TCA.
Scrap brass from the staging, machining, annealing, sanding, and fabrication areas is
collected for recycling at approximately $0.80/lb or $0.30Ab depending on the purity
of the scrap material.
The buffing process generates a considerable amount of dust that is captured in a
cyclone/baghouse and disposed of as solid waste.
Activity-Based Costs
The evaluation of process economics is extremely important in helping to determine
where the most fruitful pollution prevention alternatives lie. An activity-based costing
table for the electroplating operation was prepared as part of the ECM assessment
conducted in 1995. This table (Table 5) lists all of the waste streams from the silver
plating process across the top. Activities that occur at the facility related to
environmental compliance, waste treatment, storage or disposal are listed in the left-hand
column. By summing up all the activity-based costs for each waste stream, it is possible
to determine which waste streams are the most costly and therefore the most desirable to
minimize or eliminate.
The numbers presented in Table 4 are rough, order-of-magnitude (ฑ30%) costs based on
the approximate amount of time or materials used in an activity and average unit costs for
the activity. An empty box in Table 4 is an indication that the assessment team felt that
the cost for that particular activity was insignificant or that data was not available.
Conclusions and observations from the numbers presented in Table 4 include:
The distillation unit requires labor and electricity to operate. Depreciation of capital
to purchase the unit is another cost. These costs are off-set, however, by the savings
associated with reduced wastewater monitoring. Prior to installation of this unit,
C.M. Almy conducted weekly monitoring at a cost of approximately $6,500 per year.
The most expensive waste stream from the silver plating process is the used cyanide-
containing filters. In addition to hazardous waste disposal, costs for managing this
waste stream include hazardous material training, reporting/manifesting, and labeling.
The second most expensive waste stream is the flowing rinses. These rinses, which
generate approximately 600 gpd of wastewater, are discharged to the city sewer
system. Major costs are associated with sewer disposal fees and the cost of semi-
annual monitoring.
5
-------
Other costs are associated with disposal of spent plating and cleaning solutions, l ne
costs presented here are average annual costs based on the fact that each plating bath
is disposed of only once every few years.
In summary, although C.M. Almy generates several hazardous waste streams from their
plating process, they have greatly minimized the amount of these waste streams and their
associated costs over the last few years.
6
-------
SECTION 3 - Compliance Evaluation
RCRA / Hazardous Waste
Hazardous Waste on Site During the 30 September 1996 Site Visit
The hazardous waste observed in the flammable storage room during the 30 September
1996 visit consisted of the following:
One 30 gallon closed container with 35-40 pounds(dry) of used wipes and
filters contaminated with cyanide.
Two 5 gallon containers of liquid cyanide waste. Both the dry and liquid
cyanide waste were stored on a containment pallet to contain the hazardous
waste in case of a leak or a spill.
One 5 gallon container of liquid from the acid plating bath sitting on the floor.
The other potentially hazardous waste observed was the partially full 55 gallon drum of
lacquer stripper (MagiSol) which may be hazardous due to its low flash point. C.M.
Almy sent a sample of the lacquer stripper waste out for TCLP and flash point analysis
on October 12,1996. The test results indicated that the waste is not hazardous.
C.M. Almy has a cold storage building located opposite the loading dock on the other
side of Ruth Road. It contains only cardboard and other raw materials used by C.M.
Almy that are not affected by cold temperatures. The cold storage building was not
visited as part of this assessment so neither hazardous waste issues nor other issues were
addressed for this building.
Hazardous Waste Generator Status
The waste stored in the flammable storage room would amount to around 165 lbs/75 kgs.
This is well within the Small Quantity Generator (SQG) status. However, to maintain
this SQG status C.M. Almy must generate less than 100 kilograms of waste per month
which is equivalent to approximately 25 gallons of waste with a density of 8.9 lb/gallon,
that of CM. Almy's plating bath liquids.
C.M. Almy must periodically "change out" (empty and dispose of) a plating bath and
replace it with new solution. For any one bath, this occurs less frequently than once
per year. Nonetheless, the waste generated in this change out is classified as hazardous.
C.M. Almy does not generally measure the exact volume of waste that is disposed of
when a plating bath is changed out, but if the plating bath was filled to the top, it would
be approximately 33 gallons.
7
-------
In order to maintain its small quantity generator status, C.M. Almy must
ensure that amount of liquid removed from a plating bath for disposal in any
one month is less than 25 gallons. This would amount to approximately a
13 inch depth in the plating tank.
If C. M. Almy exceeds the 25 gallons threshold, they would have to comply with all the
requirements of a Large Quantity Generator, including, but not limited to the
following:
Obtaining an EPA ID number (already done - MED 985 467 356)
Personnel training in the recognition and handling of hazardous waste
Contingency plan
90 day storage (hazardous waste must be shipped of site within 90 days of it
being generated)
Additional storage requirements and record keeping for the hazardous
waste/flammable storage room
For a complete list of the LQG standards refer to the "State of Maine
Handbook for Hazardous Waste Generators and Chapter 850 - Hazardous
Waste Management Rules."
Air Emissions
At this time C.M. Almy & Son is not subject to state air licensing regulations.
Observations and explanations follow:
No incinerator or municipal waste combustor exists at the facility. The existence of
either an incinerator or municipal waste combustor may cause CM Almy & Son to be
subject to federal emissions standards. Statutory authority for this item comes from
38 MRSA ง590.
Total boiler capacity is 3.3 million BTU's per hour INPUT, much less than the 10
million BTU's per hour threshold. The Department of Environmental Protection
regulates boiler emissions under Chapter 115 "MAJOR AND MINOR SOURCE AIR
EMISSION LICENSE REGULATION" through the Bureau of Air Quality's licensing
program. Chapter 115 was recently revised and became effective October 6,1996.
Statutory authority for this item comes from 38 MRSA ง590.
8
-------
Many of the plating baths have vapors that volatilize from the surface of the baths and
are exhausted to the outside via exhaust slots (lip exhausts) that sit above the baths.
The slot above each individual plating bath or tank is controlled by a manual damper
in the PVC exhaust duct above each of the plating lines. A negative pressure is
established and continually maintained in the PVC exhaust. Consequently, the
plating line operator is able to control vapor in the breathing zone through use of the
manual damper. Since the size of the plating baths are so small (approximately 28
gallons) any air emissions from these tanks will be well below the threshold which
would cause an air regulation to come into affect. Examples of reporting thresholds
are 200 lbs per year of cyanide and 200 lbs per year of hydrochloric acid for the State
of Maine Hazardous Air Pollutants (HAP's) reporting via Chapter 137 "EMISSION
STATEMENTS".
Almy & Son has one paint spray booth. In this paint spray booth, a vinyl lacquer is
sprayed onto the finished product to form a protective coating (primarily to prevent
tarnishing). Both the lacquer and the lacquer thinner (reducer) presently used contain
volatile organic compounds (VOC's). The state standard for control of VOC's in paint
coating operations is Chapter 129, "SURFACE COATING FACILITIES". Although
the operation (surface coating) is controlled by this state regulation, the emission
limits for companies that coat "miscellaneous metal products" only apply if VOC
emissions exceed 15 lbs/day. Companies that emit less than 15 lbs/day of VOC's are
required to submit an Initial Certification Report, keep monthly records of coatings
use, and to store all VOC-containing materials in vapor tight containers.
Based on purchasing records for October 1995 through September 1996, C.M. Almy
used no more than 20 gallons of lacquer and 44 gallons of lacquer thinner. The VOC
contents of these materials are as follows:
Lacquer: 5.67 lbs VOC per gallon
Lacquer Thinner 6.58 lbs VOC per gallon
Based on these numbers, C.M Almy emitted 403 lbs pf VOC's over this period which is
equivalent to 1.7 lb/day using 240 working days. C.M. Almy submitted their Initial
Certification Report in 1995 as required by Chapter 129.
Clean Water Act
Wastewater Requirements
The discharge of wastewater from an industrial source, including metal finishing facilities
such as C.M. Almy, is generally covered by the Federal Clean Water Act or the Safe
Drinking Water Act. It may also be covered by the Maine Department of Environmental
Protection, Title 38, Chapter 3, Protection & Improvement of Waters statutes or the
Maine Department of Human Services subsurface wastewater disposal rules, Chapter
241.
9
-------
These Federal and State regulations target three types of industrial discharges: direct
discharges to surface waters; indirect discharges, which include any wastewater from an
industrial facility that is discharged to a municipal wastewater treatment plant, also
known as a publicly-owned treatment works (POTW); and, underground discharges of
wastewater which include septic systems.
C.M. Almy discharges sanitary and industrial process wastewater to the Pittsfield
Wastewater Treatment Facility. Therefore, C.M. Almy is an indirect discharger. The
Federal pretreatment regulations apply to the indirect discharge of the industrial
wastewater. Federal pretreatment requirements can be broken down into two types:
requirements for general industry (known as general pretreatment standards) and
requirements for specific industries (known as categorical pretreatment standards). Both
the Federal general pretreatment standards and categorical pretreatment standards apply
to C.M. Almy's discharge of industrial process wastewater. The Pittsfield Wastewater
Treatment Facility is not required to administer a pretreatment program. However, C. M.
Almy should contact Pittsfield Waste Water Treatment Authority and make sure all
required local permits are obtained.
Monitoring and recordkeeping requirements for indirect dischargers are contained in 40
CFR Section 403.12. The records for all samples must be maintained for at least three
years. These records must include:
date, place, method, and time of sampling and the names of the person(s) taking the
sample;
date(s) the laboratory performed the analyses and the analytical methods used;
laboratory that performed the analysis; and
results of the analyses.
It appears that C.M. Almy is monitoring its industrial process for the
required pollutants and that there were no monitoring and
recordkeeping deficiencies noted during the site visit on September
30,1996.
Note: The U.S. Environmental Protection Agency (EPA) is the
administering agency for the Federal pretreatment regulations and
can be contacted at (617) 565-9078 for more information on
pretreatment compliance.
Stormwater Requirements
Certain industrial facilities which discharge stormwater must apply for coverage under a
Federal stormwater permit. A facility must obtain a stormwater National Pollutant
Discharge Elimination System (NPDES) permit if the answer to all three of the following
questions is YES:
10
-------
1. Do you have a storm water discharge?
YES - C.M. Almy does have a positive collection system and it does
culminate in both pipes and ditches.
2. Does the point source discharge to regulated waters?
YES - The collection system discharges to the Sebasticook River.
3a. Are you considered an industrial activity subject to the regulations?
YES - The facility is a Standard Industrial Code (SIC) 2389 and 3471.
3b. Is there exposure or potential exposure of raw materials, finished products, by-
products or material handling equipment to storm water? The stormwater regulations
indicate that loading and unloading is one of the items defined as material handling.
There is a storm drain and ditch that conveys stormwater form the truck loading
and unloading area. Raw materials and products are handled in this area.
Therefore, one could say there is potential exposure of raw materials to
stormwater. However, under normal circumstances there is no potential for these
materials to be exposed to stormwater. All trucks unloading materials back up to
the loading dock so the materials go directly into the building without being
exposed to the weather. In addition, all the raw materials and products handled in
this area are enclosed in containers. Furthermore, all trash dumpsters and other
waste and material handling equipment is indoors.
CM Almy has the choice of either obtaining a stormwater permit or not obtaining
a permit. A conservative approach will lead CM Almy to obtain a stormwater
permit. A more typical approach would be for CM Almy not to apply for a
permit. If this is the case, it is highly recommended that C.M. Almy document
why the permit is unnecessary.
CM Almy should decide whether or not to obtain a stormwater permit and
then perform the necessary actions. The requirements are explained later in
the paragraphs labeled "Stormwater" under Regulatory Compliance
Alternative in SECTION 4 - Identification/Evaluation of P2 Alternatives.
Site Development
The Department of Environmental Protection regulates major developments and activities
on the land that substantially affect the environment. This includes the construction of
buildings, parking lots, roads, payed areas, or other areas that are not revegetated, that
occupy a total ground area in excess of 3 acres as well as developments in excess of 20
acres, metallic mineral mining, and subdivisions. Construction activities completed
before October 15,1973 are generally not included in the 3 acre calculation.
11
-------
The following is a table of the site location development at C.M. Almy, Pittsfield, Maine:
Development
Area
Construction Date
Building No. 1
11,415 m
1968
Expansion
5,824 fa
1972
Expansion
6,039 m
1976
Expansion
17,071 ft2
1981
Expansion
494 ft2
1987
Cold Storage Building
3,200 ft2
1984
Parking/Roads
49,916 ft2
1990
Total
93,959 ft2 2.16 acres
43,560 ft2 = 1 acre
Based on the site location development history provided, the facility
does not require a Site Location of Development permit.
The shoreland zone generally covers all land within 250 feet of the normal high waterline
of any great pond, river or saltwater body, within 250 feet of the upland edge of a coastal
or freshwater wetland, or within 75 feet of the high-water line of a stream, unless a local
municipality has adopted provisions to further increase the limits of this zone. C.M.
Almy does have buildings within the shoreland zone.
C.M. Almy should contact the Local Code Enforcement Officer or the
Local Planning Board to determine compliance with any applicable
local shoreland zoning regulations.
The Natural Resources Protection Act (NRPA) protects coastal wetlands, sand dunes,
freshwater wetlands, great ponds, rivers, streams, brooks, fragile mountain areas, and
significant wildlife areas. It protects these areas from unreasonable impact, degradation,
or destruction such as those that can occur during construction projects.
No construction was occurring and no current erosion was obvious so
Natural Resources Protection Act (NRPA) regulations were not
considered. Should any of the following activities occur in, on, over,
or adjacent to a protected natural resource (such as the Sebasticook
River) then C. M. Almy should contact the DEP to obtain a permit.
Activities requiring a permit include:
dredging, bulldozing, removing, or displacing of soil, sand,
vegetation, or other materials
draining or otherwise dewatering
filling.
12
-------
Fuel Storage Management / Underground Storage Tanks
According to DEP records C.M. Almy replaced an existing 2000 gallon oil tank with a
cathodically protected 2000 gallon tank around April 25,1986. During this time all tank
installations were governed by the April 5,1986 version of Chapter 691-Regulations for
Registration, Installation, Operation and Abandonment of Underground Oil Storage
Facilities.
Die following observations are based on the September 30, 1996 site visit and an office
file review:
ป The 2000 gallon UST did not have any leak detection monitoring as required by
Section 6(C)9(5) of the April 5, 1986 version of Chapter 691. This section requires
that consumptive use tanks in excess of 1100 gallons must have either groundwater
monitoring where technically practicable( a minimum of two wells - one at each end -
and monitored weekly with the results kept in a log) or secondary containment.
ป If monitoring wells were chosen as the leak detection option then a 3 gallon spill
bucket would need to be installed around the fill pipe or an approved automatic
shutoff device to control spills during delivery must be employed. It should be noted
that a vent whistle is not considered to be an automatic shutoff device but rather an
overfill alarm.
ป While the fact the vent was only a few inches above grade is not in itself a violation
this practice could lead to water infiltration and possible internal corrosion. The
UST's current cathodic protection system (as do most) only protects against external
corrosion.
~ The results of the October 31,1995 cathodic protection testing by certified
underground tank installer Michael Knapp seems to indicate that the cathodically
protected tank and associated vent and fill pipes are being protected from corrosion.
ป The copper suction and return lines seem to be sleeved in ABS plastic piping per
Chapter 691.
to bring this facility into compliance C. M. Almy has two choices: 1)Install monitoring
veils and monitor the wells weekly. 2) Remove the underground heating oil tanks and
presumably) install heating oil tanks inside the building.
13
-------
SECTION 4 - Identification/Evaluation of P2 Alternatives
Regulatory Compliance Alternatives
Hazardous Waste
C.M. Almy would like to maintain their status as a small quantity generator (SQG). In
order to do this, C.M. Almy will need to track the amount of hazardous waste that they
generate per month. In particular, they will need to measure the amount of waste
generated during a plating bath change out. The amount must be kept below 25 gallons
to stay below the large quantity generator threshold of 100 kg (220 lbs) in a month. In
those months where close to 25 gallons of plating waste is generated, no other hazardous
waste could be generated.
If C.M. Almy is not able to stay below the 100 kg (220 lbs) threshold, they will need to
review the LQG compliance requirements (summarized in Section 3 and itemized in
detail in the attached DEP Handbook for Hazardous Waste Generators) and fill any
compliance gaps in their existing hazardous waste management system. Since C.M.
Almy already has an EPA Generator number, provides secondary containment for then-
waste storage area, and conducts daily inspections, the additional LQG requirements
would not be great.
Underground Storage Tank (UST)
As indicated in Section 3.0, C.M. Almy's fuel oil storage is not in compliance with
Maine's UST regulations. To bring the facility into compliance C.M. Almy has two
alternatives: 1) Install monitoring wells around the UST and monitor the wells weekly as
required under Chapter 691; or 2) Remove the underground heating oil tank and install a
heating oil tank(s) inside the building.
Based on the fact that this system was installed soon after the law came into effect and
only has a single-walled (as opposed to double-walled) tank and piping with no leak
detection, C.M. Almy's best alternative may be to move their oil storage inside to an
aboveground system. The National Fire Protection Code 31 allows up to 660 gallons of
storage inside a building (without special building requirements) while the Maine Board
of Oil and Solid Fuel rules allow 990 gallons of storage. If C.M. Almy stays under a
single tank of 660 gallons aboveground or an aggregate of 1320 gallons, no federal Spill
Prevention Control and Countermeasure (SPCC) plan would be required. (However, a
general facility spill plan is recommended.)
Stormwater
As indicated in Section 3, a conservative interpretation of the Federal Stormwater
regulations would say that there is potential exposure of raw materials and products at
C.M. Almy's loading dock and therefore a stormwater permit is required. In reality, all
of the material that goes thougli the loading dock is enclosed in a container and therefore
the material itself is not actually exposed to stormwater.
14
-------
If C.M. Almy were to take the conservative route and apply for a storm water permit, then
it should submit a Notice of Intent (NOI) to be covered by the Multi-Sector General
Permit which EPA required companies to submit by March 29, 1996. It does not make
sense to apply for the Baseline General Permit because all Baseline General Permits
will expire in September of 1997. All companies having Baseline General Permits will
then be required to apply for the Multi-Sector General Permits.
C M Almy's Multi-Sector General Permit will cover two SIC Codes, 2389 (Apparel)
and 3471 (Electroplating, Plating and Polishing). The requirements for both SIC codes
must be met, and many are similar, but, in general it is the requirements of the 3471 SIC
Code that demand more effort and cost form CM Almy. The Multi-Sector General
Permit for both SIC codes requires a Stormwater Pollution Prevention Plan (SWPP) for
which EPA has issued significant guidance. Some of the basic requirements of the SWPP
include: a pollution prevention team; an annual site evaluation; and industry specific best
management practices. Further, a company in the 3471 SIC Code is required to conduct
quarterly stormwater monitoring in the second year, and also in the fourth year of the
permit if the second year monitoring results exceed benchmark limits. The monitoring
must include collection of stormwater samples and analysis for aluminum, zinc, and
nitrate+ni trite nitrogen. Quarterly visual stormwater monitoring would also be required
under the multi-sector permit.
However, if CM Almy has a high level of comfort that there is no potential for a
stormwater discharge then C M Almy may choose not to obtain a permit. If CM Almy
chooses not to obtain a permit, then it should retain a record on-site documenting why the
company does not need a stormwater permit. This record does not need to be submitted
to the EPA or to the State. In drafting this document, CM Almy should refer to the "EPA
Summary Guidance on Developing P2 Plans and Best Management Practices". They
may also want to include in this document such items as a list of materials received
through the loading dock, spill control and prevention practices, and housekeeping
practices. Please note that this document need not be long and its preparation need not be
burdensome.
Pollution Prevention Alternatives
As part of the assessment, the team identified and discussed several pollution prevention
alternatives. Some of the alternatives listed below have already been evaluated by C.M.
Almy and ruled out as technically or economically impractical. They are still included
here, however, to document that they have been considered.
lyfinimiTe/F-liminate dumping of plating haths - Depending on the specific plating
tank, disposal of each tank currently occurs once every 1 to 6 years as the level of
contamination gets too high to allow the bath to operate effectively. This is standard
plating industry practice. Hie baths are already filtered on a continuous basis to
extend bath life by removing organic and particulate contamination. Because they
15
-------
are small tanks and disposal is not very frequent, the cost savings of eliminating or
minimizing disposal would only be at most $500/yr.
Substitute an Aqueous Based Lacquer - C.M. Almy has experimented with a number
of aqueous lacquers and found none that will adhere sufficiently well to C.M. Almy's
parts. The problem appears to be that their aqueous cleaner (which they installed a
few years ago to replace trichloroethane vapor degreaser) does not clean the parts well
enough to allow proper adhesion. The Toxic Use Reduction Institute (TURI) in *
Lowell, MA has a surface cleaning laboratory that may be able to assist C.M. Almy
find a better cleaner. Contact Carol LeBlanc at (508) 934-3275.
Non-cvanide Plating Chemistry - C.M. Almy has been looking for a non-cyanide
silver plating bath. Technic, Inc. in Providence Rhode Island has developed a non-
cyanide plating chemistry. C.M. Almy has tried this chemistry on their parts, but
testing has shown that it can not provide the durability and brightness that C.M. Almy
needs.
Minimize overflow rate in rinse tanks - C.M. Almy has already cut water use in
flowing rinses by placing flow restrictors on the water lines and by allowing flow
only when parts are being plated. Other methods of reducing flow include
counterflow rinsing and spray rinsing. Spray rinsing may not work well at C.M.
Almy because most of the plated objects are cups which would be difficult to rinse
effectively. Counterflow rinsing may reduce flow, but would require extra tanks and
space. In addition, because water flow is already so low, the additional reduction
may not provide a significant benefit.
Find reeve)e/reuse outlet for nvlon from machining candles - Approximately 100
lb/month of nylon scrap is generated from the candle production process. This
amount is too small amount for most recyclers to try to take advantage of.
One potential source is Crowe Rope that may be able to use the nylon in their product
once it is up and running. Another possible source is the Maine Materials Exchange
which is sponsored by the Maine Chamber of Commerce. The contact for this
organization is Harold Arndt at 865-6621.
flpplace paper towels with cloth rags in plating mnm - Approximately 1 case/ week of
paper towels is used. These towels are disposed of after one use. Cloth rags could
be used as a replacement for paper towels and the cloth rags could be reused. Scrap
gloves from the buffing room could be used as the source of the rags.
16
-------
Section 5 - Implementation
The CLEAN-P2 Project Agreement that C.M. Almy signed on 8/26/96 outlines the
commitments that C.M, Almy, the U.S. EPA, and the DEP made as part of the CLEAN-
P2 project. Two of the major items that C.M. Almy committed to under this agreement
were to:
Address any areas of non-compliance identified during the assessment (through
pollution prevention where possible).
Implement one or more pollution prevention alternatives identified in the CLEAN-P2
assessment that go beyond compliance.
Develop a pollution prevention action plan which lists all the P2 projects
recommended in the CLEAN-P2 assessment report.
This section of the CLEAN-P2 assessment report lists the recommended actions that
C.M. Almy will undertake to meet these obligations.
Compliance-Based Actions
Compliance issues identified during the assessment were described in Section 3. The
actions that C.M. Almy will take in response to these compliance issues are described
below.
Hazardous Waste
In the months when C.M. Almy changes out a plating bath solutions, their waste
generation approaches the SQG/LQG threshold of 100 kilograms (220 lbs) of hazardous
waste. C.M. Almy does not object to complying with the Large Quantity Generator
requirements, but they would rather not have the stigma of a "Large Quantity Generator
of Hazardous Waste" if at all possible. Therefore, C.M. Almy will monitor and keep
records of the amount of hazardous waste generated per month to ensure that it is below
the 100 kg (220 lbs) threshold. This monitoring will ensure that the volume of plating
bath generated for disposal in any one month is less than 25 gallons.
Underground Storage Tank
C.M. Almy's underground heating oil tank (UST) was found not to be fully in
compliance with Maine's UST regulations. To come into compliance, C.M. Almy has
agreed to remove the UST and replace it with an above ground storage tank(s) located
inside the building. The AST will be installed according to applicable standards as
provided to C.M. Almy as part of this assessment.
Stormwater
CM Almy does not need an industrial stormwater permit. Documentation for this
conclusion will be prepared and kept in CM Almy's files. In preparing the document,
17
-------
CM Almy should refer to the "EPA Summary Guidance on Developing P2 Plans and
Best Management Practices". They may also want to include in this document such items
as a list of materials received through the loading dock, spill control and prevention
practices, and housekeeping practices.
"Beyond Compliance"Projects
The motivation for "Beyond Compliance" projects should be to prevent pollution oj in
some other way minimize releases, or the potential for releases, to the environment.
These motivation for projects must not solely be to meet environmental compliance
requirements.
Installation of Aboveground Fuel Storage
The minimum requirement for C.M. Almy to come into compliance with the UST
regulations would be to install monitoring wells around the tank. C.M. Almy has agreed
to go beyond this minimal standard of compliance by removing the UST and replacing it
with an aboveground tank located inside the building. By installing the tank inside, C.M.
Almy will be virtually eliminating the potential for release of oil into the environment
that exists with USTs.
Schedule
The CLEAN-P2 agreement specifies the schedule for correcting areas of non-compliance.
Generally, C.M. Almy has up to 90 days following this report to implement corrective
measures for non-compliance issues. An additional 90 days may be allowed in certain
cases if the corrective measures are outlined in a written agreement. An example of this
is the underground oil tank removal. Because this report is being issued in early 1997
and the most convenient time for the removal is during the annual, 2 week shutdown in
July, additional time beyond 90 days will be allowed and incorporated into the written
agreement. Finally, up to one year is allowed if the corrective measures involve
pollution prevention.
Based on these general guidelines, the following schedule will apply:
Action
Date (from CLEAN report completion)
Monitor/track hazardous waste generation
on a monthly basis
Was initiated in December 1996
Remove UST and replace with AST
180 days
Prepare stormwater documentation
90 days
18
-------
Attachments
C M Almy & Son
Clean P2 Assessment
-------
Attachments
C. M. Almy & Son
Table 1 Materials Accounting Table - Overall Operation
Table 2 Materials Accounting Table - Silver Plating Operation
Table 3 Materials Accounting Table - Lacquer Process
Figure 1 Overall Process Flow Diagram
Figure 2 Silver Plating Process Flow Diagram
-------
ฃ9 5E&ASTICC3C>K. R. \ Vฃ&>-
RetiKeMEmt
HouSlA/6
C.A.alky I SDA/
Pitts f/elD, Aai me
Site Pla*/ for. CLEAA/-P2 PiL.br P/toTZCr
AsSESSMEA/f 30 SEP ? (o
feo/M Flood AsszhbM ea/T SrutoV MAP- Ach&HOA/
SeZMCBS " SePT.H,
DK.AW/V AY: FT MouUOU
D ATg S J~A/Y / 9^7*7
SCALE? /"cfilo'-
1#ฃE7 ฃ ar t
-------
Figure 3. Lacquer Process Flow Diagram
wastewater
to sewer
(64 galfyr)
-------
Table 1 - Materials Accounting Table
Overall Operation
Process Step1
Amount
Amount
Unit Operation
Raw Materials
(per month)
Unit Cost ($)
Waste Materials
(per month)
Unit Cost ($)
Staging
Brass
900 lbs
3.5/lb
Scrap brass
220 lbs (a)
(0.80/lb)
Machining
paraffin-soap
Scrap brass
220 lbs (a)
Kool-cut
used speedi-dry
Speedi-dry
contaminated brass
Hydraulic Oil (Mobil)
Waste hydraulic oil
Annealing
quench water
15 gal/day
waste quench water
15 gal/day
propane
Sanding
sanding belts
600 belts/yr
6/belt
used belts
600 belts/yr
dust/sweepings
100 lb (recycled)
(0.30/lb)
Fabrication
solder flux
1 gall/yr
smoke
solder
3 spools/yr
wastewater
40 gal/2 wks
super pickle
6 gal/yr
Sodium bicarbonate
75 Ibs/yr
Finishing
see detail
Assembly/Packaging
(a) total from machining and staging
-------
I I I Table 2 - Materials Accounting Table
1 1 Silver Plating Operation
I
Process Step/
taw Materials
Cost
Cost
Unit Operation
Amount
[Unit or total)
Waste Materials
Amount
(Unit or total)
Alkaline clean
Penatone
4 gal
14.20/gal
Penatone solution dump
50 gal
- .
0.3 gpm
evaporation
Electrodean
NaOH solution
29 lbs
4/lb
NaOH dump
50 gal
water rinse
0.3 gpm
evaporation
rinsewater
0.3 gpm
Acid clean
15% HCL solution
28 gallon bath
acid dump
10 gal/yr
700 (total)
water rinse
0.3 gpm
evaporation
rinsewater
0.3 gpm
Copper Strike
CuCN and KCN
50-60 Ibs/yr
evaporation/fumes
(1,200/yr) (a)
copper anodes
spent filter
8/yr (15 lbs)
Flo-King filter
8/yr
rinsewater
(still rinse)
Silver strike
KCN and AgCN
spent plating solution
10 gal/yr (b)
8/yr(i5lbs)
(1,200/yr) (a)
Flo-King filter
8/yr
spent filter
(1,200/yr) (a)
evaporation/fumes
Silver Plate
KCN and AgCN
spent plating solution
30 gall/yr (b)
12/yr (20 lbs)
(1,200/yr) (a)
(1,200/yr) (a)
Flo-King filter
12/yr
spent filter
silver anodes
evaporation/fumes
(still rinse)
rinsewater
Wipe
paper towels
1 case/wk
waste paper towels
1 case/wk
(a) Total of all waste streams denoted
(b) amount averaged per year based on actual disposal only once every 2 to 4 years
-------
Table 3
Materials Accounting Table
Lacquer Process
Process Step/
Cost
Cost
Unit Operation
Raw Materials
Amount
Unit or total)
Waste Materials
Amount
(Unit or total)
Strip
Magisoi Stripper
60 gal/yr
Waste water/solvent
Water rinse
0.3 gpm
Air emissions
Lacquer
Acrylic
20 gal/yr
Air emissions
404 Ibs/yr
Thinner
44 gal/yr
Empty containers
-
Air filters
Spent air filters
Dry
Coated Part
Air Emissions
included above
-------
Figure 1. Overall Prnrarea F|ow Diagram
-------
Figure 2. Silver Plating Process Flow Diagram
arts from buffing.
discharge to sewer
^ every 2 weeks
discharge to sewer
every 2 wks
vapors
Penatone/water
Solution
dispose of bath
1/yr
NaOH/water
~to sewer
water
spent filter
~vapors
60
Acid Clean
(15% HCL)
discharge
I*" to sewer
vapors^
filter J
HCUwater
.~spent filter
[ r__ return-
water
KCN
and CuCN Cu heat
anodes
vapors^
filters dispose of
*bath every 6 yr
dispose of bath
every 2 yrs
~Clean water to rinse
Concentrate to plating
~ bath (61)
filter.
vapors^
KCN and f
AgCN
to
"^"buffing
water from distiller
towels
G VSMAREDป>ROGRAซSซCซiM>ROJITSX4AUOrCMAlMr*)GURESWGPlATJV3
-------
APPENDIX B
-------
-PA Consent Agreement and Order.
wysiwyg://9/http://es. inel.gov/oeca7fedfac/fedcases/cafo.html
Envirฎ$en$e
Model Consent Agreement and Final Order
Explanatory text is indicated in bracketed italics type, preceded by the word Note. Placeholder text in
which fact specific information should be inserted is indicated in bracketed text.
August 1995 revision.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION __
BEFORE THE ADMINISTRATOR
In the Matter of)
)
[Respondent's Name]) Docket No.
[Respondent's Address])
Respondant)
CONSENT AGREEMENT AND ORDER
Complainant, the United States Environmental Protection Agency ("EPA"), having filed the
Complaint herein on [date] against Respondent [Respondent's Name], the Parties herein; and
Complainant and Respondent having agreed that settlement of this matter is in the public interest,
and that entry of this Consent Agreement and Order without further litigation is the most appropriate
means of resolving this matter;
NOW, THEREFORE, before the taking of any testimony, upon the pleadings, without adjudicatioi
of any issue of fact or law, and upon consent and agreement of the Parties, it is hereby Ordered and
Adjudged as follows:
I. PRELIMINARY STATEMENT
1 - EPA initiated this proceeding for the assessment of a civil penalty, pursuant to [statute and
regulations].
2. The Complaint alleges that Respondent [describe conduct] in violation of [relevant legal
requirements].
3. Respondent filed an Answer and requested a hearing pursuant to [statute and regulations].
4. This Consent Agreement and Order shall apply to and be binding upon Respondent, its
officers, directors, servants, employees, agents, successors and assigns, including, but not
limited to, subsequent purchasers.
5. Respondent stipulates that EPA has jurisdiction over the subject matter alleged in the
Complaint and that the Complaint states a claim upon which relief can be granted against
Respondent. Respondent waives any defenses it might have as to jurisdiction and venue, and,
without admitting or denying the factual allegations contained in the Complaint, consents to
the terms of this Consent Agreement and Order.
6. Respondent hereby waives its right to a judicial or administrative hearing or appeal on any
issue of law or fact set forth in the Complaint.
8/27/97 12:04 PM
1
-------
EPA Consent Agreement and Order.
wysiwyg://9/http://es.inel.gov/oeca/fedfac/fedcases/cafo.h
II. TERMS OF SETTLEMENT
7. Pursuant to section of [statute], the nature of the violations, Respondent's
agreement to perform a SEP and other relevant factors, EPA has determined that an
appropriate civil penalty to settle this action is in the amount of [ dollars
($ )]
[Note: In order to avoid conflicts with the Miscellaneous Receipts Act, the civil penalty
provisions must be drafted separately from the provisions for implementation of the SEP.]
8. Respondent consents to the issuance of the Consent Agreement hereinafter recited and
consents for the purposes of settlement to the payment of the civil penalty cited in the
foregoing paragraph and to the performance of the Supplemental Environmental Project.
[Note: Remember that the Respondent must consent to the issuance of the Final Order and the
performance of the SEP]
9. Within thirty (30) days of receiving a copy of this Consent Agreement and Order signed by the
EPA Regional Administrator, Region , Respondent shall submit a cashier's or certified check,
to the order of the "Treasurer, United States of America," in the amount of [ dollars
($ )],to:
EPA Region
P. O. Lock Box _
[address]
Respondent shall provide a copy of the check to:
Regional Hearing Clerk
[Regional Address]
and
[Attorney Name and Address]
Interest and late charges shall be paid as specified in Paragraph 21 herein.
10. The penalty specified in Paragraph 7, above, shall represent civil penalties assessed by EPA
and shall not be deductible for purposes of Federal taxes.
11. [Description of the SEP]
a. Respondent shall complete the following supplemental environmental project ("SEP"),
which the parties agree is intended to secure significant environmental or public health
protection and improvements. Within thirty (30) days of receiving a copy of this Consent
Agreement signed by the Regional Administrator, Respondent shall [brief description of
SEP].
b. Respondent shall complete the SEP as follows: [Identify key components of the SEP; a
milestone schedule may be appropriate if implementation will take longer than 6 months].
The SEP is more specifically described in the scope of work (hereinafter, the "Scope of
Work"), attached hereto as Exhibit A and incorporated herein by reference.
[Note: Ensure that the description of the project to be performed is clear, complete and
specific. Almost all the details of the project should be set forth in the CAFO or scope of
work; negotiations over the type and scope of the SEP must be completed prior to
finalization of the CAFO.]
12. [If applicable] [New chemical not more toxic than eliminated chemical] Respondent
anticipates that the facility will use [new chemical] as a substitute for [eliminated chemical] in
the new systems constituting the SEP. In no event, however, shall any substitute chemical be
used in connection with the SEP which is more toxic or hazardous than [new chemicall as
such characteristics are described on the material safety data sheet (MSDS) for [new chemical]
attached hereto as Exhibit B.J J
l of 8
8/27/97 12:C
-------
ฎ Consent Agreement and Order.
wysiwyg://9/http://es.inel.gov/oeca/fedfac/fedcases/cafo.html
13. [Cost of SEP] The total expenditure for the SEP shall be not less than [e.g., $x to purchase the
equipment and $y to operate the equipment each year for z years], in accordance with the
specifications set forth in the Scope of Work. Respondent shall include documentation of the
expenditures made in connection with the SEP as part of the SEP Completion Report.
14. [Certification that SEP is not otherwise required]
Respondent hereby certifies that, as of the date of this Consent Agreement, Respondent is not
required to perform or develop the SEP by any federal, state or local law or regulation; nor is
Respondent required to perform or develop the SEP by agreement, grant or as injunctive relief
in this or any other case.
Respondent further certifies that it has not received, and is not presently negotiating to receive,
credit in any other enforcement action for the SEP.
[Note: This language emphasizes that the SEP is not required by any other law (federal, state
or local); nor is it required by any other agreement, grant or as injunctive relief in the instant or
any other case. In addition, the language precludes Respondent from attempting to obtain
double credit for the same project. Also, Respondent cannot be allowed to "bank" projects (i.e.
Respondent is not to be given credit for projects it has already commenced or completed in
advance of the enforcement action by EPA.)]
15. [SEP Reports]
a. SEP Completion Report Respondent shall submit a SEP Completion Report to EPA by
[construction/installation completion date]. The SEP Report shall contain the following
information:
i. A detailed description of the SEP as implemented;
ii. A description of any operating problems encountered and the solutions thereto;
iii. Itemized costs, documented by copies of purchase orders and receipts or canceled
checks;
iv. Certification that the SEP has been fully implemented pursuant to the provisions of
this Consent Agreement and Order;and
v. A description of the environmental and public health benefits resulting from
implementation of the SEP (with a quantification of the benefits and pollutant
reductions, if feasible).
b. Periodic Reports Respondent shall submit any additional reports required by the Scope of
Work to EPA in accordance with the schedule and requirements recited therein. (Note:
For any SEP where implementation is expected to exceed one year, EPA should require
submission of periodic reports by Respondent).
c. Respondent agrees that failure to submit the SEP Completion Report or any Periodic
Report required by subsections a) and b) above shall be deemed a violation of this
Consent Agreement and Order and Respondent shall become liable for stipulated
penalties pursuant to paragraph 20 below.
d. Respondent shall submit all notices and reports required by this Consent Agreement and
Order to [specify name and address] by first class mail.
16. [If applicable] [EPA right to inspect] Respondent agrees that EPA may inspect the facility at
any time in order to confirm that the SEP is being undertaken in conformity with the
representations made herein.
[Note: Consistent with the provisions below for Failure to Complete SEP and EPA To Judge
Achievement of SEP, this language provides vehicle for EPA to exercise its discretion in
determining if SEP has been completed satisfactorily and whether stipulated penalties should
be assessed.]
17. [If applicable:] [Respondent must use SEP] Respondent shall continuously use or operate the
8/27/97 12:04 PM
-------
EPA Consent Agreement and Order.
wysiwyg://9/http://es. inel.gov/oeca/fedfac/fedcases/cafo.hti"
systems installed as the SEP for not less than [number] year(s) subsequent to installation, and
Respondent shall not reinstate the use of [toxic chemical] at any time.
18. [Document retention and certification] Respondent shall maintain legible copies of
documentation of the underlying research and data for any and all documents or reports
submitted to EPA pursuant to this Consent Agreement, and Respondent shall provide the
documentation of any such underlying research and data to EPA within seven days of a
request for such information. In all documents or reports, including, without limitation, the
SEP Report, submitted to EPA pursuant to this Consent Agreement, Respondent shall, by its
officers, sign and certify under penalty of law that the information contained in such document
or report is true, accurate, and not misleading by signing the following statement:
I certify under penalty of law that I have examined and am familiar with the information
submitted in this document and all attachments and that, based on my inquiry of those
individuals immediately responsible for obtaining the information, I believe that the
information is true, accurate, and complete. I am aware that there are significant penalties
for submitting false information, including the possibility of fines and imprisonment.
19. [EPA acceptance of SEP Report]
a. Following receipt of the SEP Report described in paragraph 15 above, EPA will do one
of the following: (I) accept the SEP Report; (ii) reject the SEP Report, notify the
Respondent, in writing, of deficiencies in the SEP Report and grant Respondent an
additional thirty (30) days in which to correct any deficiencies; or (iii) reject the SEP
Report and seek stipulated penalties in accordance with paragraph 20 herein.
b. If EPA elects to exercise option (ii) above, EPA shall permit Respondent the opportunity
to object in writing to the notification of deficiency or disapproval given pursuant to this
paragraph within ten (10) days of receipt of such notification. EPA and Respondent shall
have an additional thirty (30) days from the receipt by the EPA of the notification of
objection to reach agreement. If agreement cannot be reached on any such issue within
this thirty (30) day period, EPA shall provide a written statement of its decision to
Respondent, which decision shall be final and binding upon Respondent. Respondent
agrees to comply with any requirements imposed by EPA as a result of any such
deficiency or failure to comply with the terms of this Consent Agreement and Order. In
the event the SEP is not completed as contemplated herein, as determined by EPA,
stipulated penalties shall be due and payable by Respondent to EPA in accordance'with
paragraph 20 herein.
20. [Stipulated Penalties for Failure to Complete SEP/Failure to spend agreed-on amount]
a. In the event that Respondent fails to comply with any of the terms or provisions of this
Agreement relating to the performance of the SEP described in paragraph 11 above
and/or to the extent that the actual expenditures for the SEP do not equal or exceed the
cost of the SEP described in paragraph 13 above, Respondent shall be liable for stipulated
penalties according to the provisions set forth below:
* i . 1. /ซซ\
i Except as provided in subparagraph (ii) immediately below, for a SEP which has not
been completed satisfactorily pursuant to this Consent Agreement and Order,
Respondent shall pay a stipulated penalty to the United States in the amount of $ [50
-100 percent of the amount by which the settlement penalty was mitigated on
account of the SEP].
4 of 8
8/27/97 12:<
:04^
-------
EPA Consent Agreement and Order.
wysiwyg://9/http://es.inel.gov/oeca/fedfac/fedcases/cafo.html
amount by which the settlement penalty was mitigated on account of the SEP].
iv. If the SEP is satisfactorily completed, and the Respondent spent at least 90 percent
of the amount of money required to be spent for the project, Respondent shall not be
liable for any stipulated penalty.
v. For failure to submit the SEP Completion Report required by paragraph 15(a) above,
Respondent shall pay a stipulated penalty in the amount of $ [amount] for each day
after [date in paragraph 15] until the report is submitted.
vi. For failure to submit any other report required by paragraph 15(b) above,
Respondent shall pay a stipulated penalty in the amount of $ [amount] for each day
after the report was originally due until the report is submitted.
b. The determinations of whether the SEP has been satisfactorily completed and whether the
Respondent has made a good faith, timely effort to implement the SEP shall be in the sole
discretion of EPA.
c. Stipulated penalties for subparagraphs (v) and (vi) above shall begin to accrue on the day
after performance is due, and shall continue to accrue through the final day of the
completion of the activity.
d. Respondent shall pay stipulated penalties within fifteen (15) days of receipt of written
demand by EPA for such penalties. Method of payment shall be in accordance with the
provisions of paragraph 9 above. Interest and late charges shall be paid as stated in
paragraph 21 herein.
e. Nothing in this agreement shall be construed as prohibiting, altering or in any way
limiting the ability of EPA to seek any other remedies or sanctions available by virtue of
Respondent's violation of this agreement or of the statutes and regulations upon which
this agreement is based, or for Respondent's violation of any applicable provision of law.
[Note: Language included for payment of an additional penalty for non-completion of
SEP or failure to expend amount of funds committed to in Consent Agreement must not
appear to give EPA a choice between: 1) collection of an additional penalty; or 2)
additional SEP expenditures by Respondent. Such a provision might appear to give EPA
control or discretion over the use of penalty dollars. Unlike a SEP, all assessed penalty
dollars must be deposited in the Treasury.]
21. Payment Provisions: Pursuant to 31 U.S.C. Section 3717, EPA is entitled to assess interest and
penalties on debts owed to the United States and a charge to cover the cost of processing and
handling a delinquent claim. Interest will therefore begin to accrue on a civil or stipulated
penalty if it is not paid by the last date required. Interest will be assessed at the rate of the
United States Treasury tax and loan rate in accordance with 4 C.F.R. Section 102.13(c). A
charge will be assessed to cover the costs of debt collection, including processing and handling
costs and attorneys fees. In addition, a non-payment penalty charge of six (6) percent per year
compounded annually will be assessed on any portion of the debt which remains delinquent
more than ninety (90) days after payment is due. Any such non-payment penalty charge on the
debt will accrue from the date the penalty payment becomes due and is not paid. 4 C.F.R.
Section 102.13(d) and (e).
[Note: Penalty and interest provisions and recovery of attorneys fees may vary by statute. If
appropriate, substitute a statute-specific collection authority in this paragraph. The maximum
non-payment penalty charge is six (6) percent unless a statute specifically provides otherwise.]
22. [Public statements must acknowledge enforcement action]
Any public statement, oral or written, in print, film, or other media, made by Respondent
8/27/97 12:04 PM
-------
EPA Consent Agreement and Order.
wysiwyg://9/http://es.inel.gov/oeca/fedfac/fedcases/cafq
making reference to the SEP shall include the following language, "This project was
undertaken in connection with the settlement of an enforcement action taken by the U.S.
Environmental Protection Agency for violations of [citation to legal requirements violated]."
23. [No relief from compliance; no endorsement by EPA]
This Consent Agreement and Order shall not relieve Respondent of its obligation to comply
with all applicable provisions of federal, state or local law, nor shall it be construed to be a
ruling on, or determination of, any issue related to any federal, state or local permit, nor shall it
be construed to constitute EPA approval of the equipment or technology installed by
Respondent in connection with the SEP under the terms of this Agreement.
24. [Force Majeure~if appropriate and requested by Respondent]
a. If any event occurs which causes or may cause delays in the completion of the SEP as
required under this Agreement, Respondent shall notify Complainant in writing within 10
days of the delay or Respondent's knowledge of the anticipated delay, whichever is
earlier. The notice shall describe in detail the anticipated length of the delay, the precise
cause or causes of the delay, the measures taken and to be taken by Respondent to prevent
or minimize the delay, and the timetable by which those measures will be implemented.
The Respondent shall adopt all reasonable measures to avoid or minimize any such delay.
Failure by Respondent to comply with the notice requirements of this paragraph shall
render this paragraph void and of no effect as to the particular incident involved and
constitute a waiver of the Respondent's right to request an extension of its obligation
under this Agreement based on such incident.
b. If the parties agree that the delay or anticipated delay in compliance with this Agreement
has been or will be caused by circumstances entirely beyond the control of Respondent,
the time for performance hereunder may be extended for a period no longer than the delay
resulting from such circumstances. In such event, the parties shall stipulate to such
extension of time.
c. In the event that the EPA does not agree that a delay in achieving compliance with the
requirements of this Consent Agreement and Order has been or will be caused by
circumstances beyond the control of the Respondent, EPA will notify Respondent in
writing of its decision and any delays in the completion of the SEP shall not be excused.
d. The burden of proving that any delay is caused by circumstances entirely beyond the
control of the Respondent shall rest with the Respondent. Increased costs or expenses
associated with the implementation of actions called for by this Agreement shall not, in
any event, be a basis for changes in this Agreement or extensions of time under section
(b) of this paragraph. Delay in achievement of one interim step shall not necessarily
justify or excuse delay in achievement of subsequent steps.
25. Respondent hereby agrees that any funds expended in the performance of the SEP shall not be
deductible as a business expense for purposes of Federal taxes. In addition, Respondent hereby
agrees that, within thirty (30) days of the date it submits its Federal tax reports for the calendar
year in which the above-identified SEP is completed, it will submit to EPA [identify EPA
official] certification that any funds expended in the performance of the SEP have not been
deducted from Federal taxes.
[Note: If Respondent is not willing to agree to this provision, omit it but then the after-tax cost
of the SEP should be used in the Calculation of the Cost of the SEP. See page 12 of the
Interim Revised SEP Policy.]
26. This Consent Agreement and Order constitutes a settlement by EPA of all claims for civil
penalties pursuant to [cite statute] for the violations alleged in the Complaint. Nothing in this
Consent Agreement and Order is intended to nor shall be construed to operate in any way to
resolve any criminal liability of the Respondent. Compliance with this Consent Agreement and
6 of 8
8/27/97 12:04 PNjj
-------
xhti EPA Consent Agreement and Order.
wysiwyg://9/http://es.inel.gov/oeca/fedfac/fedcases/cafo.html
Order shall not be a defense to any actions subsequently commenced pursuant to Federal laws
and regulations administered by EPA, and it is the responsibility of Respondent to comply
with such laws and regulations.
27. Each undersigned representative of the parties to this Consent Agreement certifies that he or
she is fully authorized by the party represented to enter into the terms and conditions of this
Consent Agreement and to execute and legally bind that party to it.
28. Each party shall bear its own costs and attorneys fees in connection with the action resolved by
this Consent Agreement and Order.
For Complainant: For Respondent:
, Director President
Division
U.S. Environmental Protection
Agency, Region
Date:
Company
Date:
Assistant Regional Counsel
Date:
III. ORDER
The foregoing Consent Agreement is hereby approved and incorporated by reference into this
Order. The Respondent is hereby ordered to comply with the terms of the above Consent
Agreement, effective immediately.
Date:
[Regional Administrator or delegatee]
[Title]
U.S. Environmental Protection Agency
Region
Esq.
[Firm Name]
Date:
Return to the top of this document.
Return to SEP Guidance Documents
Return to SEP Home Page
Return to Federal Facilities Enforcement Cases
^ Return to Enforcement Policy Index
7 of 8 8/27/97 12:04 PM
-------
EPA Consent Agreement and Order.
wysiwyg://9/http://es.inel.gov/oeca/fedfac/fedcases/cafo
Return to Enviro$en$e Home Page
Last Updated: May 15, 1996
URL: http://es.inel.gov/oeca/fedfac/fedcases/cafo.html
8 of 8
------- |